Motion 7: Name the Source — Who Said What, and When

You cannot cross-examine a rumor. You cannot confront an anonymous claim. If I am being accused, restricted, or threatened with jail because of something someone said, I am entitled to know who said it, when, and whether the State relied on it.

This motion requires the charging narrative to be tied to specific, identified sources — not a moving story that changes every time it's retold.

The motion as filed — page one.

What I'm asking the court to do

Order the State to identify and produce:

• Every person who made a statement to law enforcement, and what they said.
• Every statement by the complainant, the complainant's spouse, any bystander, and any church staff, member, or security person.
• Every public video, post, screenshot, or comment officers or the State reviewed.
• Every source used to support any claim that I pulled, pointed, brandished, drew, or fired a firearm.
• Every source used to support any public-safety or bond-risk claim.
• Every statement by any specifically identified individual in the filing that the State, HCSO, or Pretrial Services relies on.
• Continuing disclosure as sources come to light.

Why it matters

The issue is not whether witnesses may speak — of course they may. The issue is whether the State, officers, or Pretrial Services leaned on unattributed, changing, or unsupported claims to charge me, restrict me, or call me a danger. Source identification is what makes cross-examination, impeachment, and a real defense possible. A man's liberty cannot ride on "people are saying."

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 — Texas criminal discovery.
• Brady v. Maryland, 373 U.S. 83 (1963); Giglio v. United States, 405 U.S. 150 (1972); United States v. Bagley, 473 U.S. 667 (1985); Kyles v. Whitley, 514 U.S. 419 (1995) — disclosure of favorable and impeachment evidence.
• California v. Trombetta, 467 U.S. 479 (1984); Arizona v. Youngblood, 488 U.S. 51 (1988) — preservation.
• 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 reflects a specific allegation — a raised shirt and a hand on the grip.
• RYAN STATEMENT: Later public narratives escalated into "pulled," "pointed," "brandished," or "shot" claims.
• FACT: My website documents the public allegations and my denial of drawing, brandishing, pointing, or pulling a firearm.
• NEEDS AUTHENTICATION: Each public post, comment, video, and statement must be tied to a native source.

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 cannot defend against unattributed rumors or changing narratives.
• I need to know who made each statement, when, what they said, and whether the State or Pretrial Services relied on it.
• I believe some public statements about this case escalated beyond the actual allegation.

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

How a story changes is documented here: the church parking lot story changed.

The proposed order

• The State shall identify and produce all source statements, witness versions, public posts, screenshots, videos, and materials used to support the charging narrative, bond conditions, public-safety claims, or witness-credibility assessments.
• The State shall identify each person whose statement is relied upon, and the date, medium, and custodian of each statement.
• The State shall provide continuing disclosure.

The bottom line

Put a name and a date on every claim being used against me. If a statement can't be sourced, it can't be the basis for taking my freedom.