Motion 4: Show Me the Evidence — My Brady & Article 39.14 Discovery Demand

You cannot defend yourself against a story you're not allowed to see. This motion is the formal demand: under Texas's criminal discovery statute and the constitutional disclosure rules, the State must hand over the evidence that tests the accusation — every report, every recording, and every version of every account.

The motion as filed — page one.

What I'm asking the court to do

Order the State to produce:

• The charging instrument, probable-cause affidavit, and supporting documents.
• All offense reports, supplements, narratives, field notes, and drafts.
• All witness statements — complainant, spouse, bystanders, church staff and members, and third parties.
• All bodycam, dashcam, CAD, dispatch, 911 audio, and call sheets.
• All photos, videos, screenshots, messages, and social-media posts given to or obtained by law enforcement.
• All exculpatory, impeachment, bias, motive, and inconsistent-statement material.
• Records about my bond, speech, and firearm conditions — and, only if the State raises it, medical/THC testing.
• Continuing disclosure as more comes in.

Why it matters

This is not a fishing expedition. The core dispute is what actually happened at that church, what was said at the scene, and whether the public story escalated beyond the original allegation. The State cannot lean on the latest version while burying the earlier, inconsistent ones. If the first account was "hand on grip" and a later account became "pulled" or "pointed," that difference is material — and it's mine to test in front of a jury.

I've already documented the records side of this — see the bodycam motion and the Harrison County email exchange.

The law behind it

• U.S. Const. amends. V, VI, XIV and Tex. Const. art. I, §§ 10, 19 — due process, confrontation, and the right to present a defense.
• Tex. Code Crim. Proc. art. 39.14 — the Michael Morton Act; Texas criminal discovery.
• Brady v. Maryland, 373 U.S. 83 (1963) — favorable, material evidence must be disclosed.
• Giglio v. United States, 405 U.S. 150 (1972) — impeachment evidence must be disclosed.
• United States v. Bagley, 473 U.S. 667 (1985) — materiality includes anything undermining confidence in the outcome.
• Kyles v. Whitley, 514 U.S. 419 (1995) — the prosecutor must learn of favorable evidence known to police.
• California v. Trombetta, 467 U.S. 479 (1984); Arizona v. Youngblood, 488 U.S. 51 (1988) — preservation of exculpatory/useful evidence.
• Crawford v. Washington, 541 U.S. 36 (2004); Davis v. Alaska, 415 U.S. 308 (1974); Washington v. Texas, 388 U.S. 14 (1967); Chambers v. Mississippi, 410 U.S. 284 (1973) — confrontation and the right to present a defense.

The facts, and how I've classified them

• FACT: Public reporting states the allegation as a raised shirt and a hand on the grip of a firearm.
• RYAN STATEMENT: I deny drawing, pointing, brandishing, pulling, or threatening anyone with a firearm.
• RYAN STATEMENT: I called law enforcement, and the complainant/witness story changed over time.
• FACT / NEEDS AUTHENTICATION: The records-request screenshots indicate bodycam and report release/review issues existed.
• DOCUMENTED INFERENCE: If there are multiple versions of the same allegation, each one is material to impeachment and trial prep.
• NEEDS AUTHENTICATION: Native bodycam, CAD, dispatch, reports, statements, and public-post evidence must be produced.

My declaration

My name is Ryan Nichols. DOB December 6, 1990. I am the Defendant. Under penalty of perjury (Tex. Civ. Prac. & Rem. Code § 132.001):

• I am preparing to defend this case for trial.
• I need every witness version and every official record to test the accusation.
• I believe earlier statements and later public statements may not match.
• I request bodycam, CAD, dispatch, reports, notes, statements, public posts, and all source materials used by the State.

Executed June 1, 2026, in Harrison County, Texas. /s/ Ryan Nichols

Works with the full evidence set in the Master Exhibit Index (EX-001 through EX-016). Medical items EX-014/EX-015 are filed under seal and appear in no public image.

The proposed order

• The State shall produce all Article 39.14, Brady, Giglio, and trial-preparation materials by a deadline set by the Court.
• The State shall provide continuing disclosure.
• The State shall identify any withheld or redacted materials and the basis for withholding.

The bottom line

Give me the evidence before any plea pressure, bond hearing, or trial. If the bodycam contradicts the later claims, that's Brady and Giglio — and I'm entitled to all of it.