We wish to file this formal complaint to the Texas Commission on Law Enforcement and the

Jefferson County Sheriff’s Department Internal Affairs Division against Investigator Mark Ellis,
who, according to the Texas Code of Criminal Procedure - Article 2.12, is a Peace Officer. We
submit that Investigator Mark Ellis of the Jefferson County Sheriff’s Department, is guilty of
tampering with a witness, a felony, causing the witness to give false testimony, and we request
immediate and severe disciplinary action and call for an investigatory hearing and/or trials.

§ 36.05. TAMPERING WITH WITNESS. (a) A person commits an offense if, with intent to
influence the witness, he offers, confers, or agrees to confer any benefit on a witness or
prospective witness in an official proceeding or coerces a witness or prospective witness in an
official proceeding: (1) to testify falsely;
(2) to withhold any testimony, information, document, or thing;

Kimbrough, with the help of Investigator Mark Ellis, has tampered with evidence, withheld
evidence, fabricated testimony and instructed his star and bribed witness, jailhouse informer
Gary Wayne Harris, what to say in testimony against Daniel Meehan.

Similar complaints are being filed with the State Commission on Judicial Conduct against Judge
Patrick Clark, 128th District Court, Orange, Texas and the Texas Bar Association against Orange
County Prosecutor John D. Kimbrough. Mr. Ellis, was formerly an investigator working with
the Orange County Prosecutor’s office. The actions of prosecutor, judge and investigator suggest
a strong implication of a conspiracy to this date between the three and possibly others who were
involved with the February 1998 murder trial of Daniel Paul Meehan.

It wasn’t until June 2, 2008 that we learned of Mr. Ellis’ wrongdoing in the case of Daniel
Meehan that was tried in Judge Patrick’s 128th District Court and prosecuted by Orange County
Prosecutor John Kimbrough. On that date, Gary Wayne Harris in a sworn Affidavit, said that he
made a deal with John Kimbrough and Mark Ellis to give false testimony, fabricated by
Kimbrough and Ellis. Days later, a third felony charge against Harris was dropped. We therefore
call attention to the Texas Rule of Discovery, and that it is our understanding that according to
the Texas Discovery Rule, the Statute of Limitations on this crime now begins with that date of
June 2, 2008.

An Affidavit from Donald Meehan, signed June 25, 2008 is in the Daniel Meehan file, as well as
the Affidavit of Gary Wayne Harris of June, 2008, attesting to John Kimbrough’s and Mark
Ellis’ fabricating evidence for Gary Harris to use against Daniel Meehan at the trial.

Kimbrough’s motive for these actions as he told Harris was “that he needed a conviction bad.”
Kimbrough elaborated, according to Harris, “He was new in his career as district attorney and
this would make him look good in everyone’s eyes…This was his first murder case and he
wanted a conviction.” He told Harris, “Well, we’re in a position where we can do something for
you if you do something for us.” Kimbrough then rewarded Gary Wayne Harris his freedom
from facing a third felony conviction, in exchange for lying for the state in the case of Daniel
Paul Meehan.
In addition, it has been determined that Mark Ellis took a necklace that the murder victim was
wearing at the time of the killing, and that was in evidence, and gave it to the husband of the
victim. What is in question is that there was questionable court testimony by at least two
witnesses, L.C. Wilson and Mark Ellis, that the bullet which killed the victim, Selma Pieruccini,
struck the necklace, making an imprint on said necklace. There were even photographs of the
victim showing the necklace on her body. This bullet’s striking of the necklace may have caused
a ricochet that would have been different than testimony which was offered by Detective Barrett
and Ranger L.C. Wilson. However, Dr. Tommy Brown’s autopsy report would confuse any jury
or judge at the end where he says, “This was a through and through gunshot wound and the
bullet was not recovered. There was a small necklace impression measuring 1 ¼” along and to
the left of the exit gunshot wound and a ¾” necklace imprint on the upper portion of the bullet
extending upwards.” The necklace, which should have been held as evidence, was turned over to
husband Mark Pieruccini, by Mark Ellis with other personal effects. With this possible and
evident ricochet, a bullet could have gone wild and anywhere in that bedroom. However, the
police and D.A. may have wanted this evidence hidden or untold so the testimony could be that
the bullet went straight through and straight out. Dr. Tommy Brown testified to that, and since
John Kimbrough and Detective Mark Ellis have shaped Gary Harris’ testimony, Brown’s
testimony may have been false and shaped to John Kimbrough’s specifications.

Lastly, we wish to add that on information and belief, Gary Wayne Harris is now in Gist Jail for
two years on a Beaumont matter, and now also faces a third felony charge for forgery in
Chambers County and a felony charge in Orange County for auto theft. He has already escaped
the third felony conviction twice, which in Texas can bring life imprisonment. It is now believed
that once his two year SOL is up on his 2008 Affidavit (another year) that John Kimbrough or
Mark Ellis will approach him, if they haven’t already, with another “deal” to retract his retraction
and receive another get out of jail ticket, thus having Gary Harris walk free once more at the
expense of Daniel Meehan.

We ask that the Division and the Commission determine the underlying facts and, if they are
similar to the facts described above, and in an investigation and news account of KPRC Houston
Television report on Sept, 4, 2008, we ask that you take appropriate disciplinary action. A trial of
Detective Mark Ellis seems appropriate.