United States v. Nichols

Constitutional & severe grievances (25)

Severity 4 or 5 of 5. Each filed and documented during pretrial detention.

1. #1

   Constitutional Right Violations

   ConstitutionalSeverity 5/5 · 79 filings

   Filings asserting deprivation of constitutional rights during pretrial detention.

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2. #2

   Broken Grievance Process

   ProceduralSeverity 5/5 · 316 filings

   Grievances ignored, sabotaged, or marked non-grievable. US Marshalls Office determined the facility's grievance process was broken; Internal Affairs report referenced.

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3. #3

   Mental Health Treatment Denial

   HealthcareSeverity 5/5 · 92 filings

   Repeated requests for mental health treatment denied, ignored, or met with retaliatory short visits. Suicidal ideation reported and disregarded. Inmate in the next cell hung himself.

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4. #4

   Solitary Confinement Conditions

   ConditionsSeverity 5/5 · 77 filings

   Conditions in the SHU including water cuts, denial of medical care, mental-health denial. The cell next to him: a fellow inmate hung himself.

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5. #5

   Water Shut Off as Punishment

   ConditionsSeverity 5/5 · 12 filings

   Water shut off in the SHU for punitive reasons. Escalated to Step 4 grievance; investigation opened but no resolution.

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6. #6

   Officer Violence / Threats / Assaults

   Staff ConductSeverity 5/5 · 62 filings

   Documented officer threats and assaults against Ryan and other inmates.

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7. #7

   CS Gas / Mace in the Pod

   Staff ConductSeverity 5/5 · 84 filings

   Lt. Moore sprayed the entire pod, leaving inmates locked in cells unable to breathe. Two inmates injured.

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8. #8

   Brady Violations — Government Suppressed Federal Informant Evidence

   Brady / EntrapmentSeverity 5/5 · 8 filings

   AUSA Douglas Brasher told the court the government had no idea who "1% Watchdog" was and that Marcus DiPaola was not a federal agent. A year and a half after Ryan was sentenced, public-record evidence surfaced of Marcus DiPaola self-identifying as having worked for the FBI Chicago field office from 2016 to 2019 — the exact years he was embedded inside Ryan's hurricane-rescue organization. Suppressed exculpatory evidence. The foundation of an entrapment defense Ryan was denied.

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9. #9

   Denied Access to Discovery

   Sixth AmendmentSeverity 5/5 · 102 filings

   Repeatedly denied access to Evidence.com, no tablet, confiscated legal mail. Unable to properly prepare a defense — straight 6th Amendment violations.

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10. #10

    Confiscation of Legal Mail and Documents

    Sixth AmendmentSeverity 5/5 · 37 filings

    Legal mail and case documents confiscated, again preventing defense preparation.

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11. #11

    Denied Attorney Access

    Sixth AmendmentSeverity 5/5 · 154 filings

    6th Amendment violation — could not communicate with counsel.

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12. #12

    Request for Attorney Unanswered

    Sixth AmendmentSeverity 5/5 · 0 filings

    Requests for attorney access went unanswered.

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13. #23

    Coerced COVID Vaccination as Condition of Court Access

    Bodily Integrity / Court AccessSeverity 5/5 · 19 filings

    Judge Hogan made COVID vaccination a precondition to entering his courtroom for the bond hearing. Ryan went on the record refusing — was told he could not appear at his own hearing unless he took the shot. He reluctantly complied, was injured, and was still denied bond. Then the jail refused the second dose until after the window expired.

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14. #29

    Rappahannock Regional Jail — Same Treatment, Second Facility

    Conditions / Second FacilitySeverity 5/5 · 25 filings

    1,945 recreation minutes lost over two weeks, 23+ hour-per-day lockdowns formally labeled "MENTAL TORTURE," six co-signed inmate witness statements documenting denied medical care and retaliation. Corporal admitted the lockdowns were due to understaffing, not security.

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15. #32

    IGP Fraud — Backdated Entries, Coerced Signatures, "We Have No History"

    Procedural / FraudSeverity 5/5 · 124 filings

    IGP Coordinator T. Campbell repeatedly denied grievances by claiming "WE HAVE NO HISTORY" of received-stamped paperwork that Ryan has copies of. Detainees coerced into signing IGPs as "resolved" without resolution. The whole process exists as institutional cover.

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16. #33

    Marriage and Family Destroyed by Prosecution

    FamilySeverity 5/5 · 28 filings

    The pretrial detention, the indefinite separation, the denial of family visits, the intercepted mail, the inter-facility transfers — together destroyed Ryan's marriage and his relationship with his children. The cost is permanent and not theoretical.

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17. #34

    Career and Business Destroyed by Prosecution

    Damage InflictedSeverity 5/5 · 4 filings

    Years of pretrial detention without conviction destroyed Wholesale Universe, Inc. — the multi-million-dollar wholesale/retail company Ryan built from the ground up. The economic damage is documented, measurable, and direct.

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18. #13

    Lack of Food / Rotten Food

    ConditionsSeverity 4/5 · 70 filings

    Food trays missing food. Rotten food, spoiled eggs. Foreign objects in food (pubic hair, chemicals).

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19. #14

    Foreign Objects in Food

    ConditionsSeverity 4/5 · 0 filings

    Chemicals and foreign objects (pubic hair) found in served food.

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20. #15

    Denied Restroom Access

    ConditionsSeverity 4/5 · 28 filings

    Denied access to restroom and shower.

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21. #21

    COVID Outbreak in Pod

    HealthcareSeverity 4/5 · 5 filings

    COVID-19 outbreak in the pod with inadequate response.

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22. #24

    Racial Remarks from Staff

    Staff ConductSeverity 4/5 · 35 filings

    Documented racial remarks made by detention staff.

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23. #25

    Discrimination — Major Marr Email

    Staff ConductSeverity 4/5 · 72 filings

    Documented discriminatory email from Major Marr.

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24. #30

    Northern Neck Regional Jail — Co-Defendants Starved of Discovery

    Inter-Facility PatternSeverity 4/5 · 10 filings

    Co-defendant Christopher Quaglin held at Northern Neck Regional Jail with missing discovery and dangerous weight loss. Defense correspondence with Superintendent Ted Hull and the Marshals documents the same institutional pattern across yet another facility.

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25. #31

    Unannounced Inter-Facility Transfers

    Procedural / FamilySeverity 4/5 · 4 filings

    Ryan was cycled through ten different facilities during the federal case — Tyler (E.D. Tex.), Oklahoma transit, NW3 quarantine, DC DOC CTF, Rappahannock Regional Jail, Northern Neck Regional Jail, FDC Houston, Florence, Albany Jail, and post-sentence BOP — without notice, repeatedly disrupting counsel, family, religious observance, and continuity of medical care.

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Additional documented grievances (9)

Severity 1–3. Filed contemporaneously with the constitutional grievances above.

• Denial of Hygiene · 59× · severity 3/5
• No A/C in Pod · 0× · severity 3/5
• Untreated Medical Issues (Ear) · 7× · severity 3/5
• Denied COVID Testing · 0× · severity 3/5
• Denied Religious Services · 41× · severity 3/5
• Denied Video Visits · 16× · severity 3/5
• Denied Communication / Mail · 83× · severity 3/5
• Recreation Time Cut · 24× · severity 2/5
• Stolen Commissary · 20× · severity 2/5

Cast of named officials (382)

Each individually identified in Mr. Nichols' contemporaneous grievance log.

Timeline (38 events)

1. Date pending verification

   AUSA Brasher Denies Federal Ties of Marcus DiPaola and 1% Watchdog (Pre-Plea)

   Before Ryan's guilty plea, the defense filed a disclosure request asking whether Marcus DiPaola — the man inside Ryan's rescue organization who filmed the 2018 Ellen-DeGeneres-show rescue video — and 1% Watchdog — the entity that assigned Ryan rescue missions — were government assets. AUSA Douglas Brasher denied on the record that the government had any idea who 1% Watchdog was and stated that Marcus DiPaola was not a federal agent, not affiliated with the FBI, not affiliated with the feds. The denial was the predicate Brady violation. Exact filing date pending verification from the docket.

2. Date pending verification

   Charges Dismissed With Prejudice — U.S. v. Nichols

   U.S. Attorney Edward R. Martin Jr. moved to dismiss the charges in *United States v. Nichols* (1:21-cr-00117-TFH) with prejudice. Dismissal with prejudice bars the government from ever bringing the same charges again. The dismissal followed the January 20, 2025 presidential pardon and the broader Trump-administration review of January 6 cases.

3. Date pending verification

   Marcus DiPaola Federal-Informant Self-Admission Surfaces (Post-Sentencing)

   Approximately a year and a half after Ryan's sentencing — while Ryan was in federal prison — a fellow detainee surfaced a public-record archive (https://archive.ph/jYVkv) in which Marcus DiPaola self-identifies as having worked for the FBI Chicago field office from 2016 to 2019 and openly discusses having been hot-mic'd and wired in 2020. Those years align precisely with the period he was embedded inside Ryan's hurricane-rescue organization and in direct contact with Ryan. The disclosure should have been turned over pre-plea under Brady v. Maryland. It was not.

4. December 1, 2020

   Pre-Incarceration Medical Baseline — Documented PTSD, Sertraline

   Pre-incarceration medical records confirm pre-existing PTSD/anxiety diagnoses and an active Sertraline prescription before January 6, 2021. Establishes the medical baseline that DC DOC then refused to honor — central to the deliberate-indifference claim.

5. January 6, 2021

   January 6, 2021 — The Capitol

   Ryan Taylor Nichols — United States Marine Corps veteran, founder of Wholesale Universe, Inc. (a multi-million-dollar wholesale/retail company he built from the ground up), Texas Search and Rescue volunteer, and father — travels from Texas to Washington, D.C. to attend the rally. He is present at the U.S. Capitol on January 6, 2021. The detention that followed cost him his marriage and his presence in his children's daily lives.

6. January 18, 2021

   Arrest

   Ryan Taylor Nichols arrested by federal agents at his home in Longview, Texas. The arrest follows by twelve days the events at the Capitol.

7. January 22, 2021

   First Bond Hearing — Hon. K. Nicole Mitchell, Tyler, Texas (Denied)

   Ryan's first bond hearing — four days after his January 18, 2021 arrest — before Hon. K. Nicole Mitchell, U.S. District Court for the Eastern District of Texas (Tyler Division). Pretrial release denied on 1/22/21. Five cited reasons included references to planned attack, text messages regarding weapons/body armor, and threats. Confirmed in scan j6s26-004 (handwritten Nichols transcription of the ruling). Next bond hearing would not happen until December 20, 2021 — nearly 11 months later — before Judge Hogan and under coerced-vaccination preconditions.

8. January 29, 2021

   Federal Indictment

   Federal grand jury returns an indictment in United States v. Nichols and Harkrider charging Ryan with felonies in the District of Columbia. Co-defendant: Alex Kirk Harkrider.

9. January 30, 2021

   Pretrial Detention Begins

   Ordered detained pending trial — the period during which all 27 grievance categories below were filed.

10. September 30, 2021

    DC DOC Work Performance Ratings — "Excellent / Outstanding"

    June through September 2021 DC DOC Work Performance Ratings authored by Sgt. Shawn Franklin and N. Abdullah/Dubbal rate Ryan Excellent/Outstanding, recommend promotion, and explicitly note he had "no adverse action or any Disciplinary Reports" since entering CTF. Exculpatory baseline that contradicts any claim that subsequent treatment was warranted.

11. October 13, 2021

    Judge Lamberth Holds DC DOC in Contempt (U.S. v. Worrell)

    Hon. Royce C. Lamberth holds DC DOC Director Quincy Booth and Warden Patten in contempt in *U.S. v. Worrell* for the same DC Jail conditions Ryan was simultaneously experiencing. The contempt finding is cited as institutional admission in Ryan's Habeas Corpus petition.

12. October 20, 2021

    USMS Inspection of DC DOC (Standing Sewage, Food/Water Withheld)

    October 18-22, 2021 U.S. Marshals Service inspection memo documenting standing sewage, water and food withheld from detainees at the DC DOC. Attached as evidence in Ryan's Habeas Corpus petition.

13. October 25, 2021

    Motion for Reconsideration of Detention Order Filed

    Defense files a motion asking the court to reconsider pretrial detention. This motion sits between the February 2021 first bond hearing in Tyler, Texas (denied) and the December 2021 second bond hearing before Judge Hogan (where Ryan was forced to take the COVID vaccine as a precondition and was still denied bond).

14. October 26, 2021

    Sibick Witness Statements Signed

    Ryan and 10 co-defendants (Kash Kelly, Cleveland Meredith, Kelly Meggs, Ronnie Sandlin, Nathaniel DeGrave, Billy Chrestman, Jon Mellis, Robert Morss, Scott Fairlamb, Tim Hale) sign dated statements documenting alleged sexual misconduct, racial remarks, and assault by Thomas Sibick inside the C-2B pod.

15. November 7, 2021

    First Grievance Filed — Officer Discrimination

    IGP 2011223-829: Officer J. Johnson — discrimination, mental punishment, explicit language, intimidation. Marked "non-grievable."

16. November 11, 2021

    OC Spray Pod Incident

    Lt. Moore deploys OC spray through the entire C-2B pod. Inmates locked in cells unable to breathe. Documented victims: Lonnie Coffman and Dan Caldwell. Target: Bryan Mock. IGP #22111223-887 filed; denied 11/22/21 as "group grievance" by T. Campbell.

17. December 4, 2021

    Coerced First COVID Dose Administered

    First COVID vaccine dose administered to Ryan at DC DOC on December 4, 2021 — reluctantly, under the coercive precondition Judge Hogan had set for the December 20, 2021 bond hearing. Ryan documents this date in his 3/18/22 Step 4 Deputy Director appeal (scan j6s14-014).

18. December 7, 2021

    DC DOC Denies Required Second COVID Dose

    Ryan files Electronic Informal Grievance #22112144-412 (scan j6s18-016) on December 7, 2021 documenting that his required second COVID dose — scheduled for 12/01/21 to be ready for the 12/20/21 bond hearing — was refused by DC DOC officers and medical staff who told him "there were no more COVID shots available." Court access compromised; bond denied at the 12/20 hearing anyway.

19. December 7, 2021

    "Unusually Cruel" Congressional Report on J6 Detainee Conditions

    Reps. Marjorie Taylor Greene, Matt Gaetz, Louie Gohmert, and Paul Gosar publish the "Unusually Cruel" report on conditions of January 6 detainees at the DC DOC. The report becomes an institutional record cited in Ryan's Habeas Corpus petition.

20. December 20, 2021

    Second Bond Hearing — Dec 20, 2021 (Judge Hogan)

    Ryan's second bond hearing — almost a year after the first one in Tyler, Texas was denied. Judge Thomas Hogan conditioned access to this hearing on Ryan taking the COVID vaccine. Ryan went on the record stating he did not want the shot; told his attorney the same. He reluctantly took the first dose on Dec 4, 2021 to preserve access to the hearing. DC DOC then refused the required second dose until after the window expired. Bond denied at the Dec 20, 2021 hearing despite Judge Hogan's on-record admission that prolonged solitary confinement violated Ryan's due process rights. Confirmed in scans j6s14-014 (Step 4 Deputy Director Appeal, 3/18/22) and j6s18-016 (12/7/21 IGP).

21. January 3, 2022

    14-Member Congressional Letter to BOP Director Carvajal

    14-member congressional letter to BOP Director Carvajal regarding J6 detainee conditions. Carvajal's subsequent resignation is cited in the Habeas Corpus petition.

22. February 7, 2022

    C2B Group Protest Incident

    Group protest incident in the C2B pod documented in a contemporaneous incident log naming Lt. Bruce, the captain on duty, Major Sheila Marr, Officer Sulladeen, CPL Armstrong, and Head of Security Burris.

23. February 17, 2022

    Peter Stager PREA Complaint Coerced into Withdrawal

    Co-defendant Peter Stager's PREA grievance #20220201-685 (filed 2/1/22 about a female officer's "peeping tom" behavior) is followed by a coerced 2/17/22 Notice of Withdrawal signed in the presence of C. Savage. Major Sheila Marr issues a dismissive 3/21/22 response. C. Savage closes the case 3/28/22 with a timeline that contradicts the documented receipt. Stager is then written up, isolated, and loses his detail job. Pattern-evidence directly corroborating Ryan Nichols's broken-IGP claim.

24. April 20, 2022

    Mental Health Grievance 20220420-921 Filed

    Step 1/Step 2 grievance filed asserting denial of mental-health treatment. Step 2 response by Grievance Manager Beth Jordan misrepresents the number of therapist visits.

25. May 10, 2022

    Suicide Watch / Inmate Death in Neighboring Cell

    Ryan placed on suicide watch after escalating mental-health requests went unanswered. Inmate in the cell next to him later hung himself.

26. May 17, 2022

    Water-Shutoff Grievance Investigation Closed

    Investigator Lancaster signs the IGP investigation response on water-shutoff grievance 2022050-120. Escalated to Step 4; no remedy granted.

27. August 10, 2022

    Petition for Writ of Habeas Corpus Filed

    Petition for Writ of Habeas Corpus Under 28 U.S.C. § 2241 and Complaint for Declaratory and Injunctive Relief filed in Civil Action No. 1:22-cv-02356, Ryan Taylor Nichols v. Merrick Garland and Michelle Jones. Five causes of action raised: 5th Amendment deliberate indifference, 5th Amendment illegal solitary, 5th+8th Amendment cruel-and-unusual / torture, 6th Amendment interference with counsel and discovery, and 1st Amendment retaliation and religious denial. Counsel: Joseph D. McBride (NY) and Jonathan S. Gross (MD).

28. September 15, 2022

    Unannounced Transfer to Rappahannock Regional Jail

    Ryan transferred from the DC DOC Central Treatment Facility to Rappahannock Regional Jail in Virginia with no advance notice to family or counsel. Documented in the attorney/U.S. Marshals/DC DOC email chain (j6s8-005 through j6s8-009).

29. October 5, 2022

    Rappahannock Grievance Filings

    Four signed Rappahannock Regional Jail inmate grievance forms filed October 4-6, 2022, with six co-signed witness statements from fellow detainees (Dustin Gammons #51547, Richard Jong Pak #98201, Andrew Combs, Joshua Roberts #00046579, Abraham B, Worzel Jacobs #51556) documenting denied recreation, medical neglect, beatings, and retaliation.

30. October 15, 2022

    Quaglin Discovery / Weight-Loss Crisis — Northern Neck

    Email thread between defense attorney Jonathan Gross and Northern Neck Regional Jail Superintendent Ted Hull documents J6 co-defendant Christopher Quaglin's missing discovery and dangerous weight loss — institutional pattern echoing Ryan's own treatment.

31. November 4, 2022

    House Judiciary GOP — FBI Whistleblowers Report

    House Judiciary Republicans publish the FBI Whistleblowers report — exhibit attached to defense filings as institutional corroboration of weaponization claims.

32. November 1, 2023

    Medical Neglect Log (Nov 2023 – Mar 2024)

    Multi-month handwritten log by Ryan documenting denied medical care, the hamstring-injury dispute, GTL pricing complaints, and observations of Dr. Gute's practice.

33. March 1, 2024

    "Mental Torture" — 1,945 Recreation Minutes Lost

    Quantitative cruelty math entered into the formal grievance record: 1,945 recreation minutes lost over a two-week period, alongside 23+ hour-per-day lockdowns explicitly labeled "MENTAL TORTURE" in the IGP filings.

34. April 1, 2024

    2023-2024 IGP Exhaustion Campaign

    Multi-month systematic exhaustion of the four-level DC DOC Inmate Grievance Procedure (Informal → Formal → Level 1 → Level 2 → Deputy Director) on denied testosterone replacement therapy, denied Vitamin D, denied Levothyroxine, and on the broader allegation that Coordinator T. Campbell deliberately sabotages the grievance process. Required predicate for federal compensation.

35. May 1, 2024

    Notarized Witness Statement: U.S. Marshals + DC DOC Chief Confirm IGP "Broken"

    Notarized witness statement (scan j6s8-090) names U.S. Marshal Ricky Rice, Marvin T. Buckhalter, and Chief Anderton as having acknowledged the DC DOC Inmate Grievance Procedure is broken. Co-signed by Peter Stager and James McGrew. Independent federal acknowledgment of grievance-process collapse.

36. January 20, 2025

    Presidential Pardon — Executive Order

    President Donald J. Trump signs the Executive Order granting full and unconditional pardons to Ryan Nichols and all other January 6 defendants.

37. October 15, 2025

    Omnibus Motion / Motion for New Trial

    Hearing on omnibus motion including motion for new trial. Transcript available.

38. May 1, 2026

    DOJ Anti-Weaponization Fund Announced

    The U.S. Department of Justice announces the Anti-Weaponization Fund in May 2026 to compensate those harmed by the previous administration's prosecutions. This case file is being prepared for submission to that panel.

Key documents in the record (232 of 1000)

Indictments, dockets, motions, rulings, transcripts, affidavits. Personal scans and contemporaneous cell notes are catalogued at /case?view=documents.

1. affidavitSep 22, 2025Bonnie Nichols petitioner's supporting affidavit, p.1 (divorce)Open
2. orderMay 1, 2024Texas Court Register of Actions - State v. Nichols 2018-0666 Assault MisdemeanorOpen
3. orderApr 24, 2024DC DOC Denial of IGP #20240424-658 by T. Campbell 4/24/24 - untimely + redundantOpen
4. orderApr 24, 2024DC DOC Denial of IGP #20240424-677 by T. Campbell 4/24/24Open
5. orderApr 24, 2024DC DOC Denial of IGP #2024 0424-672 by T. Campbell - Multiple Issues Reason, Apr 24 2024Open
6. orderApr 24, 2024DC DOC Denial of IGP #2024 0424-675 by T. Campbell - Statement Denied, Apr 24 2024Open
7. orderApr 24, 2024DC DOC Denial of IGP #2024 0424-676 by T. Campbell - Provide Correct Steps, Apr 24 2024Open
8. orderMar 27, 2024IGP #20240313-316 with DOC response by L. Johnson 3/27/24 - video reviewOpen
9. orderMar 21, 2024DC DOC Denial of IGP Form #20240321-479 - K. Nickens 3/21/24Open
10. orderMar 20, 2024DC DOC Denial of Inmate IGP Form by T. Campbell (IGP #2024 0320-458), Mar 20 2024Open
11. orderJan 17, 2024DC DOC Denial of IGP #2024 0117-190 by T. Campbell - Late + Already Responded, Jan 17 2024Open
12. orderDec 22, 2023DC DOC Denial of IGP #2023 1222-349 by T. Campbell - Late + Already Answered, Dec 22 2023Open
13. motionSep 26, 2023Annotated exhibit: Judge Hogan Oath of Office with Recusal for Cause notationOpen
14. motionSep 26, 2023Filed exhibit: Oath of Office for Judge Thomas F. Hogan (1982)Open
15. motionOct 28, 2022Nichols Supplement to Motion for Pretrial Release - Doc 177 p.1/11Open
16. motionOct 28, 2022Nichols Supplement to Pretrial Release - Doc 177 p.10/11 - Conclusion & SignaturesOpen
17. motionOct 28, 2022Nichols Supplement to Pretrial Release - Doc 177 p.2/11 - Sept 5 incident & timelineOpen
18. motionOct 28, 2022Nichols Supplement to Pretrial Release - Doc 177 p.3/11Open
19. motionOct 28, 2022Nichols Supplement to Pretrial Release - Doc 177 p.4/11 - Washington testimony rebuttedOpen
20. motionOct 28, 2022Nichols Supplement to Pretrial Release - Doc 177 p.5/11 - Three drives explainedOpen
21. motionOct 28, 2022Nichols Supplement to Pretrial Release - Doc 177 p.6/11 - Missing blue drive & Rappahannock Sgt. FosterOpen
22. motionOct 28, 2022Nichols Supplement to Pretrial Release - Doc 177 p.7/11 - ARGUMENT Point OneOpen
23. motionOct 28, 2022Nichols Supplement to Pretrial Release - Doc 177 p.8/11 - Point Two: Sixth AmendmentOpen
24. motionOct 28, 2022Nichols Supplement to Pretrial Release - Doc 177 p.9/11 - Marshals custodian, Point ThreeOpen
25. motionOct 28, 2022Nichols Supplement to Pretrial Release - Doc 177 p.11/11 - COSOpen
26. affidavitOct 5, 2022Affidavit of Ingrid Washington - Doc 169-1 p.3/13 (Aug 29 incident)Open
27. affidavitOct 5, 2022Affidavit of Ingrid Washington - Doc 169-1 p.4/13 (Signature, conclusion)Open
28. affidavitOct 5, 2022Affidavit of Ingrid Washington - Doc 169-1 p.1 of 13Open
29. motionSep 30, 2022Defendant Reply — page 10 of 14Open
30. motionSep 30, 2022Defendant Reply — page 11 of 14Open
31. motionSep 30, 2022Defendant Reply — page 12 of 14Open
32. motionSep 30, 2022Defendant Reply — page 2 of 14Open
33. motionSep 30, 2022Defendant Reply — page 3 of 14Open
34. motionSep 30, 2022Defendant Reply — page 4 of 14Open
35. motionSep 30, 2022Defendant Reply — page 5 of 14Open
36. motionSep 30, 2022Defendant Reply — page 6 of 14Open
37. motionSep 30, 2022Defendant Reply — page 7 of 14Open
38. motionSep 30, 2022Defendant Reply — page 8 of 14Open
39. motionSep 30, 2022Defendant Reply — page 9 of 14Open
40. motionSep 30, 2022Defendant Reply to Government Opposition — page 1 of 14Open
41. motionSep 30, 2022Emergency Motion for Release - Doc 168 p.13/14 - ConclusionOpen
42. motionSep 30, 2022Emergency Motion for Release - Doc 168 p.14/14 - Signature/COSOpen
43. motionSep 28, 2022Reply to Govt Opposition p8: McBride & Gross signature, cert of serviceOpen
44. motionSep 8, 2022Doc 156 p2: Lancaster maced Maccabees, 15 witness statementsOpen
45. motionSep 8, 2022Doc 156 p3: No detox bath, mental health denied, Spanish grievance formOpen
46. motionSep 8, 2022Doc 156: Supplement to Emergency Pretrial Release p1 - Lancaster assaultOpen
47. motionSep 8, 2022Motion to Dismiss All Charges (Doc 155) page 1 with Ryans annotationsOpen
48. motionSep 8, 2022Motion to Dismiss page 2: Bidens 31 anti-MAGA statements (1-12)Open
49. motionSep 8, 2022Motion to Dismiss page 3: Bidens 31 statements (13-27)Open
50. motionSep 8, 2022Motion to Dismiss page 4: Bidens speech conclusion, US v Thomas citeOpen
51. motionSep 8, 2022Motion to Dismiss page 5: McBride signature and certificate of serviceOpen
52. motionSep 8, 2022Doc 156 p4: McBride signature & certificate of serviceOpen
53. motionAug 30, 2022Emergency Motion for Immediate Pre-Trial Release — page 1 of 12Open
54. motionAug 30, 2022Emergency Motion for Release — page 10 of 12Open
55. motionAug 30, 2022Emergency Motion for Release — page 11 of 12Open
56. motionAug 30, 2022Emergency Motion for Release — page 12 of 12 (Conclusion, Signature)Open
57. motionAug 30, 2022Emergency Motion for Release — page 2 of 12 (Background)Open
58. motionAug 30, 2022Emergency Motion for Release — page 3 of 12Open
59. motionAug 30, 2022Emergency Motion for Release — page 4 of 12 (Legal Standard, Argument)Open
60. motionAug 30, 2022Emergency Motion for Release — page 5 of 12Open
61. motionAug 30, 2022Emergency Motion for Release — page 6 of 12Open
62. motionAug 30, 2022Emergency Motion for Release — page 7 of 12Open
63. motionAug 30, 2022Emergency Motion for Release — page 8 of 12Open
64. motionAug 30, 2022Emergency Motion for Release — page 9 of 12Open
65. motionAug 12, 2022Doc 132 (8/12/22): Motion to Join Harkrider p.2 - Texaco v Short cite, GoPro noteOpen
66. motionAug 12, 2022Doc 132 (8/12/22): Motion to Join/Adopt Harkrider ECF 94 (1752 dismiss) p.1Open
67. motionAug 12, 2022Doc 134 (8/12/22): Motion to Join Harkrider Omnibus Reply ECF 117 p.1 (self-defense)Open
68. motionAug 12, 2022Doc 134 (8/12/22): Motion to Join Harkrider Reply p.2 - self-defense argumentOpen
69. motionAug 12, 2022Doc 136 (8/12/22): Motion in Limine p.2 - Legal Standard, FRE 401-403Open
70. motionAug 12, 2022Doc 136 (8/12/22): Motion in Limine p.3 - US v Berger, denies Proud Boys/militia tiesOpen
71. motionAug 12, 2022Doc 136 (8/12/22): Motion in Limine to preclude inflammatory language p.1Open
72. motionAug 12, 2022Motion to Dismiss Count Two — arbitrary application is unconstitutional (p.8 of 21)Open
73. motionAug 12, 2022Motion to Dismiss Count Two — arbitrary novel application argument (p.10 of 21)Open
74. motionAug 12, 2022Motion to Dismiss Count Two — Conclusion and WHEREFORE (p.20 of 21)Open
75. motionAug 12, 2022Motion to Dismiss Count Two — Electoral Count is ministerial, not proceeding (p.19 of 21)Open
76. motionAug 12, 2022Motion to Dismiss Count Two — Electoral Count not a contemplated proceeding (p.18 of 21)Open
77. motionAug 12, 2022Motion to Dismiss Count Two — Enron loophole legislative history (p.4 of 21)Open
78. motionAug 12, 2022Motion to Dismiss Count Two — grammatical interpretation of otherwise (p.11 of 21)Open
79. motionAug 12, 2022Motion to Dismiss Count Two — Nichols never tampered with documents (p.7 of 21)Open
80. motionAug 12, 2022Motion to Dismiss Count Two — noscitur a sociis / Yates / Begay (p.14 of 21)Open
81. motionAug 12, 2022Motion to Dismiss Count Two — selective prosecution examples (p.9 of 21)Open
82. motionAug 12, 2022Motion to Dismiss Count Two — statutory background of 1512(c)(2) (p.3 of 21)Open
83. motionAug 12, 2022Motion to Dismiss Count Two (1512(c)) — 1512(c) context argument (p.2 of 21)Open
84. motionAug 12, 2022Motion to Dismiss Count Two (1512(c)) — cover page (p.1 of 21)Open
85. motionAug 12, 2022Motion to Join Transfer Venue (Doc 135) page 1 of 6Open
86. motionAug 12, 2022Motion to Transfer Venue p3: Aguilars statement & Nicholss Pence quoteOpen
87. motionAug 12, 2022Motion to Transfer Venue p4: McBride July 21 status hearing statementOpen
88. motionAug 12, 2022Motion to Transfer Venue p5: US v North cite, Eastern District of TexasOpen
89. motionAug 12, 2022Motion to Transfer Venue page 2: court concerns, Watergate analogyOpen
90. motionAug 12, 2022Motion in Limine — exclude inflammatory descriptors (p.4)Open
91. motionAug 12, 2022Motion to Dismiss Count Two — adverb vs conjunctive adverb / Sarbanes-Oxley (p.13 of 21)Open
92. motionAug 12, 2022Motion to Dismiss Count Two — Begay analysis / surplusage canon (p.16 of 21)Open
93. motionAug 12, 2022Motion to Dismiss Count Two — grammar of otherwise (p.12 of 21)Open
94. motionAug 12, 2022Motion to Dismiss Count Two — Memorandum of Law / Legal Standard (p.5 of 21)Open
95. motionAug 12, 2022Motion to Dismiss Count Two — surplusage / 1512 review (p.17 of 21)Open
96. motionAug 12, 2022Motion to Dismiss Count Two — Yates plurality / noscitur a sociis (p.15 of 21)Open
97. motionAug 12, 2022Motion to Dismiss Count Two — Certificate of Service (p.21 of 21)Open
98. motionAug 11, 2022Doc 134 (8/12/22): Motion to Join Harkrider Reply p.3 - USCP shot first, conclusionOpen
99. motionAug 11, 2022Doc 129 (8/10/22): Nichols Motion to Continue p.2 - signed Joseph McBrideOpen
100. motionAug 11, 2022Motion in Limine — signature page with WHEREFORE list of excluded terms (p.5)Open
101. motionAug 11, 2022Motion to Join and Adopt Co-Defendant ECF 96 Motion to CompelOpen
102. motionAug 11, 2022Doc 132 (8/12/22): Motion to Join Harkrider p.3 signature/COSOpen
103. motionAug 11, 2022Motion to Transfer Venue p6: McBride signature & cert of serviceOpen
104. motionAug 11, 2022Doc 134 (8/12/22): Motion to Join Harkrider Reply p.4 - Certificate of ServiceOpen
105. motionAug 10, 2022Habeas Corpus petition — cover page (Nichols v. Garland, 1:22-cv-02356)Open
106. motionAug 10, 2022Habeas Corpus petition — page 10 (DC Jail structure / Barnett, McBride article)Open
107. motionAug 10, 2022Habeas Corpus petition — page 11 (Amnesty/ACLU request, Judge Lamberth contempt)Open
108. motionAug 10, 2022Habeas Corpus petition — page 12 (USMS inspection cover-up at CTF)Open
109. motionAug 10, 2022Habeas Corpus petition — page 13 (USMS memo findings, MTG/Gohmert visit)Open
110. motionAug 10, 2022Habeas Corpus petition — page 14 (Charles Allen roundtable, 36 detainee letter, mace incident)Open
111. motionAug 10, 2022Habeas Corpus petition — page 15 (Unusually Cruel report, Landerkin tweet)Open
112. motionAug 10, 2022Habeas Corpus petition — page 16 (Landerkin tweets, Congressional letter for resignation)Open
113. motionAug 10, 2022Habeas Corpus petition — page 17 (CTF custody transfer, Corp Allen, Lt Lancaster, Lt Moore)Open
114. motionAug 10, 2022Habeas Corpus petition — page 18 (catalog of guard misconduct)Open
115. motionAug 10, 2022Habeas Corpus petition — page 19 (Bail Modification Hearing Dec 20 2021, Judge Hogan)Open
116. motionAug 10, 2022Habeas Corpus petition — page 20 (Government concedes CDF troubling; Hogan refuses release)Open
117. motionAug 10, 2022Habeas Corpus petition — page 21 (Hogan invites habeas, Petitioner denied release, sons unseen)Open
118. motionAug 10, 2022Habeas Corpus petition — page 22 (Congressional letter signatories; Model Prisoner section)Open
119. motionAug 10, 2022Habeas Corpus petition — page 23 (Model Prisoner evaluations and good conduct)Open
120. motionAug 10, 2022Habeas Corpus petition — page 24 (First Amendment deprivation — religious services)Open
121. motionAug 10, 2022Habeas Corpus petition — page 25 (1st & 6th Amendment deprivations begin)Open
122. motionAug 10, 2022Habeas Corpus petition — page 27 (5th and 5th/8th Amendment deprivations)Open
123. motionAug 10, 2022Habeas Corpus petition — page 28 (Psychological manipulation; 19 months without seeing children)Open
124. motionAug 10, 2022Habeas Corpus petition — page 29 (Deliberate indifference to medical condition begins)Open
125. motionAug 10, 2022Habeas Corpus petition — page 3 (Introduction & Jurisdiction)Open
126. motionAug 10, 2022Habeas Corpus petition — page 30 (May 10 2022 grievance, Lt Allen, April 20 suicide watch)Open
127. motionAug 10, 2022Habeas Corpus petition — page 31 (McBride/Glover correspondence on solitary)Open
128. motionAug 10, 2022Habeas Corpus petition — page 4 (Venue & Parties)Open
129. motionAug 10, 2022Habeas Corpus petition — page 5 (Statement of Facts — Personal History)Open
130. motionAug 10, 2022Habeas Corpus petition — page 7 (Ellen DeGeneres / PTSD diagnosis section)Open
131. motionAug 10, 2022Habeas Corpus petition — page 8 (PTSD symptoms and triggers)Open
132. motionAug 10, 2022Habeas Corpus petition — page 9 (Conditions of Confinement at DC Jail begins)Open
133. motionAug 10, 2022Habeas Corpus petition — table of contents (page 1 of 2)Open
134. motionAug 10, 2022Habeas Corpus petition — table of contents (page 2 of 2)Open
135. motionAug 10, 2022Habeas Petition p.62 — Signature block Joseph D. McBride and Jonathan S. GrossOpen
136. motionAug 10, 2022Doc 129 (8/10/22): Nichols Motion to Continue trial (Lyme/Long Covid) p.1Open
137. motionAug 10, 2022Habeas Corpus petition — page 6 (Statement of Facts — rescue history)Open
138. affidavitMay 14, 2022Witness statement: Ryan Nichols — Divontay Brown suicide attempt in SHUOpen
139. affidavitMay 11, 2022Witness statement: Kelly Meggs — hate-mail received in DC Jail and at homeOpen
140. motionMay 9, 2022Habeas Petition p.32 — McBride/Glover email exchange re solitary confinementOpen
141. motionMay 9, 2022Habeas Petition p.33 — Section K Inmate Grievance Process Irreparably BrokenOpen
142. motionMay 9, 2022Habeas Petition p.34 — IGP Coordinator T. Campbell grievance handlingOpen
143. motionMay 9, 2022Habeas Petition p.35 — Steps 3 and 4 grievance: solitary, water shutoff, suicide watchOpen
144. motionMay 9, 2022Habeas Petition p.36 — Step 4 Appeal sabotaged, IGP Coordinator changed formOpen
145. motionMay 9, 2022Habeas Petition p.37 — Grievance against IGP Coordinator T. CampbellOpen
146. motionMay 9, 2022Habeas Petition p.38 — 108 grievances, 42 ignored, intimidation of J6 detaineesOpen
147. motionMay 9, 2022Habeas Petition p.39 — Grievance sabotage, Nov 11 2021 gassing of multiple prisonersOpen
148. motionMay 9, 2022Habeas Petition p.40 — Inaccessible grievance process; Section VI Legal Standard beginsOpen
149. motionMay 9, 2022Habeas Petition p.41 — Suspension Clause, 28 USC 2241 jurisdiction, Section A conditions of confinementOpen
150. motionMay 9, 2022Habeas Petition p.42 — Section B Due Process Rights of Pretrial DetaineesOpen
151. motionMay 9, 2022Habeas Petition p.43 — Section C Deliberate Indifference to Underlying Medical ConditionOpen
152. motionMay 9, 2022Habeas Petition p.44 — Section D Solitary Confinement as Punishment; Biblical and historical examplesOpen
153. motionMay 9, 2022Habeas Petition p.45 — Nelson Mandela, Eastern State Penitentiary 1829, Senator Warren on ICE solitaryOpen
154. motionMay 9, 2022Habeas Petition p.46 — Section E HALT Act, NY Solitary Confinement, Senator SalazarOpen
155. motionMay 9, 2022Habeas Petition p.47 — Section F UN Standard Minimum Rules (Nelson Mandela Rules)Open
156. motionMay 9, 2022Habeas Petition p.48 — Section G Prolonged Solitary as Torture; Section VII PRLA ExhaustionOpen
157. motionMay 9, 2022Habeas Petition p.49 — PRLA Unavailability, Thwarting Process, InterferenceOpen
158. motionMay 9, 2022Habeas Petition p.50 — Section A Petitioner Excused from PRLA ExhaustionOpen
159. motionMay 9, 2022Habeas Petition p.51 — Unavailability and Thwarting/Interference as PRLA exceptionsOpen
160. motionMay 9, 2022Habeas Petition p.52 — Intimidation, Misleading; US Marshals declared grievance process brokenOpen
161. motionMay 9, 2022Habeas Petition p.53 — Section VIII First Claim: Deliberate Indifference Violates 5th Amend Due ProcessOpen
162. motionMay 9, 2022Habeas Petition p.54 — WaPo Op-Ed by ACLU Gregg + NYCLU Liberman on solitary tortureOpen
163. motionMay 9, 2022Habeas Petition p.55 — Congressman Gohmert wellness check, 3 weeks solitary April 2022Open
164. motionMay 9, 2022Habeas Petition p.56 — Gohmert Aug 8 2022 follow-up; Second Claim: Solitary Violates Due ProcessOpen
165. motionMay 9, 2022Habeas Petition p.57 — Third Claim: Prolonged Solitary Violates 5th and 8th AmendmentsOpen
166. motionMay 9, 2022Habeas Petition p.58 — ACLU 2013 Report "A Death Before Dying" on solitary effectsOpen
167. motionMay 9, 2022Habeas Petition p.59 — Fourth Claim: 6th Amendment Right to Counsel ViolationsOpen
168. motionMay 9, 2022Habeas Petition p.60 — Fifth Claim 1st Amendment Retaliation; Section IX ConclusionOpen
169. motionMay 9, 2022Habeas Petition p.61 — Section X Prayer for Relief: release, injunction, release to wife BonnieOpen
170. affidavitMay 8, 2022Statement in defense of Ryan Nichols — page 2 (signatures)Open
171. affidavitMay 7, 2022Statement in defense of Ryan Nichols (re: Brandon Fellows tablet message) — page 1Open
172. motionApr 17, 2022Continued motion notes: Deliberate Indifference and Access to BasicsOpen
173. motionApr 17, 2022Habeas/Conditions/Discovery notes for change-of-venue, Apr 17 2022Open
174. motionApr 17, 2022Motion outline continued: informants, media, PTSD triggers, guardsOpen
175. affidavitApr 6, 2022James McGrew veteran witness statement re DC DOC (p.2, signed 4-6-22)Open
176. affidavitApr 6, 2022Jessica Watkins veteran witness statement re DC DOC (p.1)Open
177. affidavitApr 6, 2022Jessica Watkins veteran witness statement re DC DOC (p.2, signed 6 Apr 22)Open
178. affidavitMar 29, 2022Peter Stager — handwritten statement on IGP #20220201-685 irregularities and PREAOpen
179. affidavitMar 22, 2022Witnessed narrative — Major Talley conversation 3/22/22 (signed by Kelly Meggs)Open
180. motionDec 29, 2021Sean McHugh — pro se IAC motion (p.5, 12-29-21) re: emails to judge, no defenseOpen
181. motionDec 28, 2021Sean McHugh — pro se IAC motion (p.4, 12-28-21) re: Judge Bates, breakout room, Beattie articleOpen
182. transcriptDec 20, 2021Judge Hogan on the record: Ryan Nichols' due process rights were violatedOpen
183. affidavitNov 14, 2021Daniel Caldwell witness statement re DC DOC (p.2, Nov 14 2021)Open
184. motionOct 25, 2021Government's Opposition to Motion for Reconsideration of DetentionOpen
185. motionOct 25, 2021Motion for Reconsideration of Detention OrderOpen
186. affidavitSep 14, 2021Jeffrey McKellop witness statement re DC DOC solitary (p.3, signed)Open
187. docketAug 16, 2021Docket SummaryOpen
188. motionApr 23, 2021Sponsors Motion for Admission p.2 — David Bana Signature/AddressOpen
189. affidavitJan 30, 2021Nichols & Harkrider Government AffidavitOpen
190. indictmentJan 29, 2021Ryan Nichols IndictmentOpen
191. rulingJan 22, 2021Handwritten transcription — Judge K. Nicole Mitchell detention ruling (1/22/21)Open
192. motionCase Scope I.C.A.P - US v. North motion re: Congressional hearings & tainted juryOpen
193. motionCase Scope ICAP page 2 - Brady violation, Congress withholding BWC videoOpen
194. motionCase Scope ICAP page 3 - protective order asymmetry, change of venue, time served remedyOpen
195. affidavitDaniel Caldwell witness statement re DC DOC (p.1, signed top)Open
196. affidavitDaniel Caldwell witness statement re Ryan Nichols (p.3, signed)Open
197. motionDefendants Reply to Govt Opposition to Motion to Dismiss p1Open
198. motionDefense Argument Outline — 18 U.S.C. 3142(i) Temporary Release MotionOpen
199. motionDefense Argument p.2 — Thumb Drive Confiscation Makes Trial Prep ImpossibleOpen
200. motionDefense Argument p.3 — Dupree Factors, Lee, Buswell Case LawOpen
201. motionDefense Argument p.4 — Acevedo-Baldera, Stephens, Jeffries 3142(i) Case LawOpen
202. motionDefense Argument p.5 — Trial Prep Burdens, Complexity, Expense, ChressenOpen
203. motionDefense Argument p.6 — 3142(c) Factors: Not Flight Risk, Not DangerOpen
204. motionDefense Argument p.7 — Ali (Pirate), El-Hage, El-Gabrowny, Millan ComparatorsOpen
205. motionDefense Argument p.8 — Millan/Rivera Cite, Conclusion: Grant Pretrial ReleaseOpen
206. motionDefense outline p2: three drives, Aug 29 confiscation, Officer Swolwannii bodycamOpen
207. motionDefense outline: Illegal Taking of Nichols thumb drive — opening statement notesOpen
208. transcriptHearing Transcript p.18 — McBride: FBI Raid, Self-Surrender, Munchel/TaniosOpen
209. affidavitJames McGrew veteran witness statement re DC DOC (p.1)Open
210. affidavitJessica Watkins witness statement re Ryan Nichols decline in C2BOpen
211. affidavitPeter Stager — signed closing: not destroying officers, fixing a broken systemOpen
212. motionReply to Govt Opposition p2: distinguishing Tsarnaev, Skilling, Yousef, Haldeman, McVeighOpen
213. motionReply to Govt Opposition p3: Obama/Clinton/Bush counterexamplesOpen
214. motionReply to Govt Opposition p4: 9/11 counterexample, Bushs Islam is Peace speechOpen
215. motionReply to Govt Opposition p5: Bush vs Biden contrasted, calls to actionOpen
216. motionReply to Govt Opposition p6: defend our democracy, J6 Committee theoryOpen
217. motionReply to Govt Opposition p7: defend democracy in jurors box, 95% DC Biden votersOpen
218. affidavitTimothy Hale (Hale-Cusanelli #376441) veteran witness statement (signed)Open
219. motionArgument notes: influencing a juror, racial prejudice analogy, Tyler FBI/FitzerOpen
220. motionJail conditions notes: weight loss, food, Baltimore Bloods, ratsOpen
221. affidavitJeffrey McKellop witness statement re DC DOC solitary (p.1)Open
222. affidavitJeffrey McKellop witness statement re DC DOC solitary (p.2)Open
223. motionRyan notes: FOIA, Grievance Process Broken, Howard Univ HospitalOpen
224. motionSean McHugh — earlier draft IAC brief (Lexi Negin BLM, DUI/alcoholism, 2nd detention hearing)Open
225. motionSean McHugh — pro se IAC brief (cont.) re: DA from Utah / Lexi Negin trip / waived speedy trialOpen
226. motionSean McHugh — pro se IAC brief (cont.) re: Judge Howell, equal-protection, waived speedy trialOpen
227. motionSean McHugh — pro se IAC motion (p.3) re: motions, grand jury transcripts, discovery, jail treatmentOpen
228. motionSean McHugh — pro se ineffective assistance brief (caption + Lexi Negin / Maria Jacob narrative)Open
229. affidavitWitness statement: Kenneth Harrelson — hate-mail received in DC JailOpen
230. motionSean McHugh — pro se IAC motion (p.2) re: Maria Jacob waived speedy trial / coached him to nodOpen
231. motionSean McHugh — pro se motion for ineffective assistance of counsel (p.1) re: Maria JacobOpen
232. motionSponsors Motion for Admission of Jonathan Gross by David Bana (D. Md.)Open