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To: Texas State Commission on Judicial Conduct

P,O Box 12265
Austin, TX 78711-2265

We wish to file this formal complaint to the State Commission on Judicial Conduct against Judge
Patrick Clark (128th District Court, Orange, Texas) and ask that the commission take immediate
and severe disciplinary action and call for an investigatory hearing and/or trials.

A similar complaint is being filed with the Texas Bar Association against Orange County
Prosecutor John D. Kimbrough. The actions of both prosecutor and judge suggest a strong
implication of a conspiracy to this date between the two and possibly others who were involved
with the February, 1998 murder trial of Daniel Paul Meehan.

In the Petition of Habeas Corpus filed in Judge Clark’s 128th District Court, on or about July 21,
2008 in the case of Daniel Paul Meehan No. A-970268BR, evidence was presented that
Prosecutor John D. Kimbrough engaged in conduct using his office for personal gain involving
dishonesty, fraud, bribery, deceit or misrepresentation, and engaged in conduct constituting
obstruction of justice.

Included with that Petition was a CD recording and a transcript of the State’s witness, Gary
Wayne Harris, recanting his trial testimony as well as an Affidavit of Harris swearing to it, and
which enhanced and embraced evidence presented in a former denied Appeal, as were the
contents of Donald Meehan’s 55 page Affidavit with 72 Exhibits in Daniel Meehan’s
aforementioned Petition. Both Kimbrough and Judge Clark chose to ignore the Petition, the
recant of Harris’ testimony as well as his Affidavit to that effect containing the new evidence.

Lack of attention to and disposition of Daniel Meehan’s Petition of Habeas Corpus by both
Judge Clark and Prosecutor Kimbrough suggest a cover-up. It is apparent that both men strove to
hide evidence of another possible and probable suspect with obvious motives.

The entire Affidavit with 72 Exhibits is in the Daniel Meehan file and can also be viewed online
at www.scribd.com/don%20meehan along with the entire recant of Gary Wayne Harris and the
subsequent Order of Judge Patrick Clark (EXHIBIT 1) dismissing Meehan’s Petition, and
ignoring the evidence of Harris’ recant.

With the evidence presented in the Petition for a Writ of Habeas Corpus in the case of Daniel
Paul Meehan, Judge Patrick Clark had a moral and ethical obligation to have an evidentiary
hearing and call witnesses including Kimbrough, his Assistant Gary Bonneaux, Detective Mark
Ellis and Kimbrough’s paid jailhouse snitch, Gary Wayne Harris and others, but chose to ignore
new evidence presented and chose to continue to cover up actions by himself and Prosecutor
John Kimbrough and others in the trial and sentencing of Daniel Meehan and his subsequent
Petitions.
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A full evidentiary hearing would have provided an honest and complete appraisal of the
injustices imposed upon Daniel Meehan, and provide reasons to open up an investigation of the
motives of another possible suspect, the shooting victim’s husband, Mark Pieruccini.

Judge Clark has abused his official position to impede Daniel Paul Meehan’s access to his court
and thus to justice, and to present new evidence, which was also an enhancement of older
evidence and filed by Daniel Meehan with the Petition.

This misconduct by Judge Clark would include, but is not limited to, the "improper or wrongful
use of the power of his office by a judge acting intentionally, or with gross indifference to his
conduct. It involves more than an error of judgment or a mere lack of diligence. Necessarily, the
term would encompass conduct involving moral turpitude, dishonesty, corruption, misuse of
office, or bad faith generally, whatever the motive.”

This dual misconduct of Clark and Kimbrough merits an intense investigation into this case and
also into past prosecutions and convictions by this pair of prosecutor and judge, which may have
been conducted in the same conspiratorial manner.

Clark and Kimbrough both chose to ignore Gary Harris’ charges and deny the Petition, which
also denies Meehan his rights and clearly underlines the deceitful, deceptive and misleading role
played by the prosecutor, John Kimbrough, of having his “star” and paid jailhouse snitch
witness, Gary Wayne Harris, lie on the witness stand and who has now recanted that testimony,
as well as compounding Kimbrough’s malicious withholding of evidence.

At the very beginning of the trial on page two and three of the trial proceedings, John Kimbrough
moved to suppress any evidence of the motives and actions of the husband of the victim, Mark
Pieruccini, and Judge Clark allowed this motion. (EXHIBIT 2AB with Donald Meehan’s June
25, 2008 Affidavit) It is inconceivable how and why Judge Clark would utter, “Who is this
person?” in reference to Mark Pieruccini. Reasons for questioning this response is explained
below. It is inconceivable that Judge Clark would sit there and innocently ask, “Who is this
person?”

This first and immediate act of the Judge and Prosecution, in concert, certainly gives reason to
suspect a perfect setup for eliminating any suspect other than Daniel Meehan, and places total
doubt and suspicion on the integrity and lack of justice served in the trial of Daniel Meehan.

This immediate motion by Kimbrough confirms that both judge and prosecutor knew very well
of Mark Pieruccini’s actions, and that if the jury heard about them there would be more than
reasonable doubt cast upon Meehan’s guilt.

Judge Clark should have recused himself at the beginning of Meehan’s trial in 1998, since he
was definitely in a conflict of interest continuing hearing the case with his knowledge and court
actions in the matters of Selma Pieruccini, the victim, and Mark Pierucini, her husband. These
matters included marital, divorce, custody, the husband’s kidnapping, his Protective Orders,
alimony, and child support at the time of the killing, which was clearly outlined in Donald
Meehan’s Affidavit with Exhibits.
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But all of this evidence was suppressed at Daniel Meehan’s trial, and Judge Clark led all to
believe he knew not of who Mark Pieruccini was. However, close examination of both of their
actions to this day in regard to Meehan’s case suggest a strong conspiracy to enhance John D.
Kimbrough’s career at Meehan’s expense.

Judge Clark apparently knew that if he called for an evidentiary hearing at the time of Meehan’s
July, 2008 Petition for a Writ of Habeas Corpus, the actions of all involved would come before
the public and the press to be explained. And so, in an attempt to avoid embarrassment he chose
to bury it and ignore it, and in effect, hide it.

Judge Clark wrote by hand into his August 5, 2008 Order (EXHIBIT 1): “My examination of
my notes reflect that the jury had sufficient evidence to reach a verdict, even without the
testimony of Harris.” This callous handwritten statement by Clark speaks as though there is not
one word in the Petition regarding Gary Harris’ recanting of his lying testimony, and evidence of
misconduct by the Prosecutor and his investigator. Therefore, the public is supposed to accept
that handwritten note by Clark as final, and that this man’s sentence of 99 years is just alright
and justified just because Clark’s “notes” say that the jury had “sufficient evidence to reach a
verdict” make it so. Therefore, it is alright in Judge Clark’s mind that the jury did not have all the
evidence, including Kimbrough’s lies, or that an evidentiary hearing might, indeed, bring forth
the truth. And so, Clark does not even address, acknowledge or allow Harris’ sworn statement
about the “deal” made with Kimbrough and Mark Ellis to lie for them on the stand, and to be told
by them what to say.

We submit that this act by Judge Clark to totally ignore the sworn statements and Affidavit of
Gary Wayne Harris was a gross error that adds to the charge of a conspiracy and cover-up.
Harris’ entire sworn recant is with Donald Meehan’s Affidavit in Daniel Paul Meehan No. A-
970268BR file, and that, as well as the trial transcript, can also be viewed online at
www.scribd.com/don%20meehan.

Gary Wayne Harris has confirmed the statements and/or affidavits from six (6) other witnesses
that he lied on the witness stand, and now he has admitted that he was told what to say and how
to say it in several meetings with Investigator Mark Ellis and John Kimbrough.

RULE 18b. GROUNDS FOR DISQUALIFICATION AND RECUSAL OF JUDGES

(2) Recusal. A judge shall recuse himself in any proceeding in which:

(a) his impartiality might reasonably be questioned;

(b) he has a personal bias or prejudice concerning the subject matter or a party, or personal
knowledge of disputed evidentiary facts concerning the proceeding;

Not known or presented to the jury was the evidence that the wife victim had applied for and
received a severe protective Order in August, 1996 against her husband. The Order had been
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processed by Assistant DA Gary Bonneaux, assistant prosecutor in Meehan’s trial, served by

Texas Ranger, L.C Wilson, who was a Prosecution witness and signed by Judge Clark.
(EXHIBITS 30ABCD and EXHIBITS 31ABC with Donald Meehan’s June 25, 2008 Affidavit)
Each of these three failed to inform the jury of husband Mark Pieruccini’s violent behavior
toward his wife. When the Order was mysteriously dismissed or withdrawn right after the
August date, the husband immediately kidnapped the children and took them to Pennsylvania
without the wife’s permission. Court papers filed as Exhibits with the aforementioned Petition
indicate that Clark was aware that the husband had kidnapped the couple’s children and had
taken them to Pennsylvania. (EXHIBIT 34ABCDE with Donald Meehan’s June 25, 2008
Affidavit) There is no evidence to indicate that any of the parties in Orange County, who knew
of this kidnapping, followed the rule of the National Child Search Assistance Act, 42 USC
5779-80 of 1990, requiring each federal, state, and local law-enforcement agency to enter
information about missing children younger than the age of 18 into the Federal Bureau of
Investigation's (FBI) National Crime Information Center (NCIC) database.

Judge Clark had personal knowledge of the victim in the shooting and her jealous husband,
regarding Restraining Orders he had signed, and ongoing divorce hearings. Events and
EXHIBITS of the Orange County Divorce case and the Pennsylvania Custody case are all in and
with the Affidavit of Donald Meehan, which Clark had in his hands at the time of Daniel
Meehan’s July 19, 2008 Petition.

We submit a brief background here from Donald Meehan’s 2008 Affidavit of events involving
Judge Clark in the lives of Mark and Selma Pieruccini.

Selma Pieruccini had filed an application for a Protective Order on husband Mark
Pieruccini in Orange County, Texas and a TEMPORARY EX PARTE PROTECTIVE
ORDER AND SHOW CAUSE ORDER
(EXHIBIT 30A-B-C-D) was issued on August 12, 1996 signed by Judge Pat Clark. This
Order and the Divorce proceedings begun by Selma Pieruccini later in 1997, were all
held in the court of Judge Pat Clark, the same judge who presided in Meehan’s case.
Judge Pat Clark found that there “is a clear and present danger of family violence unless
Mark Pieruccini is ordered to do or refrain from certain acts,” which amounted to 2
(two) pages. A hearing was set for August 26, 1996 in Judge Pat Clark’s Orange, Texas
court, and Mark Pieruccini was ordered to appear A harsh WARNING (EXHIBIT 30D)
regarding contempt of court and fines and jail time for violation of the order, was issued
with these papers. These documents, which had been filed in Orange County, Texas,
were obtained from the Cumberland County, PA. Custody Case file started by Mark
Pieruccini a few days after kidnapping the children from Orange, Texas in September,
1996. Selma Pieruccini’s Texas complaint papers and APPLICATION FOR
PROTECTIVE ORDER from Judge Pat Clark’s court had also been filed in the
Cumberland County, PA. Custody case and were retrieved from that file. (EXHIBIT
31A-B-C-D) from that file claimed that “Respondent (husband, Mark) has engaged in
conduct that constitutes family-violence as follows: Respondent pushed Applicant into a
dryer and threw Applicant onto the dryer. Respondent also grabbed Applicant by the neck
and threw her to the floor. Applicant has bruises and soreness as a result of Respondent’s
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actions. Respondent stated to Applicant that he intends to remove the children from the
state and never return them. Along with the application in the Order of Protection, Mark
Pieruccini was ordered by Orange County, Texas Judge Clark, among a long list of other
things, not to take the four children away from the jurisdiction of Orange County. Mark
then charmed and sweet talked Selma into dropping the charges and Order of Protection
and on August 29, 1996, Asst. DA Gary Bonneaux filed a motion to dismiss the
Protective Order (EXHIBIT 32) stating, “Applicant no longer wishes to pursue
protective order.” On the same document, EXHIBIT 32, there is an Order dated
September 3, 1996 signed by Judge Pat Clark dismissing the cause and lifting the
Protective Order. Two love notes written in Orange, Texas, and submitted in evidence by
Sela Pieruccini, were found in the Cumberland County, Pennsylvania Custody file
(EXHIBITS 33A-B), whereas the husband wrote apologies and said, “We are going on a
trip – be back in a few days.” - The following day, September 4, 1997, set free from the
Order, Mark fled the jurisdiction and left for Pennsylvania with the children the very next
day on Sept. 4,- and arrived in Shippensburg, Pennsylvania on Sept. 6, 1996. He
immediately filed for Custody in Cumberland County Court and listed all of his
accusations about Selma and apparent lies and reasons why the children should be with
him and not with her. A conciliation meeting was ordered and scheduled on Dec. 11,
1996 in Pennsylvania and Selma could not attend, but was represented by her legal
services attorney. On December 4, 1996 Selma Pieruccini filed a “ PETITION
REQUESTING THAT THIS COURT DECLINE JURISDICTION” in the Court of
Common Pleas of Cumberland County, PA (EXHIBIT 34 A-B-C-D-E-F) wherein she
claimed, “i --The father wrongfully took the children from their home in Texas and
brought them to Pennsylvania without the consent of the mother and over her objections.
ii—The father intended to benefit his position in custody by convincing the mother to
withdraw the Protection from Abuse action she had filed against him in Texas and by
removing the children from the custody of their mother when the Texas court vacated the
Temporary Protection Order which gave the mother custody. Furthermore, after the
father fled to Pennsylvania, he deprived the mother of housing by having her utilities
disconnected, blocking her access to insurance cards which she needed to register her car,
and threatening her safety at the marital residence. Additionally, the father harassed the
mother at her place of employment causing her to lose her job.” After conferences broke
down, Judge Hess, on February 13, 1997, issued an Order for a hearing on April 23, 1997
in Cumberland County, Pennsylvania. Selma filed for Divorce in Orange County, Texas
on April 16, `1997, one month before the killing, and the new TEMPORARY
RESTRAINING ORDER AND ORDER SETTING HEARING FOR TEMPORARY
ORDERS SIGNED BY Judge Pat Clark set a hearing date for April 28, 1997 and re-
issued the same heavy restraining order on husband Mark with the original 2 (two) pages
of restrictions (EXHIBIT 35A-B-C-D-E). So, before any Order had come down from the
Pennsylvania court regarding custody, Judge Pat Clark included in his Order of April 16,
1997 above, on EXHIBIT 35C, “Petitioner (Selma) should be appointed temporary
managing conservator,” until the April 28, hearing, whereas Judge Clark would decide
permanent managing conservator or custody in Texas. With this Order, Selma now
actually had custody in Texas from April 16, 1997 to approximately May 10, 1997 when
the May 5 Order was served on Mark. Receiving this May 5 (Texas) Order from Judge
Pat Clark obviously infuriated Mark Pieruccini and stirred thoughts of having his wife
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eliminated. Selma obviously believed and told friends she had a strong case for custody,
and awaited the May 15, 1997 (Pennsylvania) Order anxiously with high hopes, but Mark
had strong arguments in Pennsylvania and had already set at least one child against her
mother with a letter from a social worker that the daughter did not want to live with her
mother at this time (EXHIBIT 36).

Although Clark attempted at Meehan’s trial to appear to the jury that he didn’t know who this
Mark Pieruccini was, it is inconceivable and a lie that he knew nothing of the couple’s marital
and custodial conflicts, and in effect, lied to the people by his omission. Events and EXHIBITS
of the Orange County Divorce case and the Pennsylvania Custody case are all in and with the
Affidavit of Donald Meehan, which Clark had in his hands at the time of Daniel Meehan’s July
19, 2008 Petition.

Clark had issued an Order of temporary weekly spousal support of $115.38, until a final decree
would be signed (EXHIBIT 40ABCB with Donald Meehan’s June 25, 2008 Affidavit). And so,
the divorce was proceeding in Clark’s court at the time of her death.

Absence of any language pertaining to child custody and/or child support in his Order of May 5,
1997 indicates that he was well aware of the Pennsylvania custody proceedings brought by the
husband, which gave the couple joint custody, and ordered that the children would be in the
wife’s custody for the summers.

We stress that Clark was and still remains in a severe conflict of interest in these matters.
It is clear from his actions that Judge Clark can no longer be expected to preside over murder
cases with the requisite fair, bias-free and even-handed disposition so critical to such serious
matters concerning guilt or innocence. Clark is unfit to be a judge and should be removed from
office.

Justice was not served in the Daniel Meehan case. We stress that most importantly, Judge
Clark’s denial of the Petition, and not calling for a hearing to hear witnesses constitutes a
flagrant violation of human rights.

The Judicial Councils Reform and Judicial Conduct and Disabilities Act of 1980 (Section 372 of
Title 28 of the United States Code) defines judicial misconduct as "conduct prejudicial to the
effective expeditious administration of the business of the courts." Courts have interpreted this to
include fraudulent, corrupt, immoral, illegal and dishonest behavior and any physical or mental
incapacity to carry out judicial duties. We submit that both Clark and Kimbrough are guilty of
lying to the public by omission.

Putting aside all logic and obligations to investigate any and all possible suspects, the district
attorney, the investigating team and officers blatantly, with the assistance of Judge Pat Clark,
intentionally disregarded, withheld and/or kept secret the possibility of Mark Pieruccini’s
involvement in the murder.

Full details of these matters were explained thoroughly in paragraphs 19—23 in Donald
Meehan’s June 25, 2008 Affidavit.
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All documents spoken of here, continuing divorce hearings, alimony, temporary orders, are all
signed by Judge Pat Clark, but the record does not indicate that Ms. Rogers was able to make
that fact known for the jury, the record and the public. Judge Clark states in the record that he
“probably would rule that they wouldn’t have been admissible.” And I refer here to Daniel
Meehan’s Punishment phase of his trial on February 5, 1998, page 40, 41, 42, 43, 44 (EXHIBIT
3A,B,C,D,E with Donald Meehan’s June 25, 2008 Affidavit). Outside of the presence of the
jury, Attorney Rogers states: “Your Honor, I requested to get into some information about the
marriage and pending divorce of Selma and Mark Pieruccini, as well as the evidence that she
(Selma) was well aware of how to remedy a situation if there was family violence or if there was
a problem. And I have subpoenaed the records of the Orange County Sheriff’s office, which
shows calls made by her husband Mark, as well as her. I have a certified copy of the protective
order filed against Mark Pieruccini and the original petition for divorce and temporary orders
that were in that divorce case, and I ask that they be added. Had I been allowed to talk about that
evidence, this is what I would have presented.” And this is where Clark said he “probably
would rule that they wouldn’t have been admissible.” He also states: “The evidence that the
Court remembers that you had asked to go into was a protective order.” Yes, a protective order
signed by him. And yes, that statement indicates that indeed, he did remember, bur chose to
pretend to “forget.”
It was obvious that Judge and Prosecution wanted no mention of the husband’s wrongdoing, nor
any reference to the fact that the papers discussed were all from Judge Clark’s court.
It was also withheld from the jury, according to Gary Harris’ sworn account, that Ms. Rogers
had represented Prosecution witness, Gary Harris in months prior on a criminal case; another
conflict of interest not disclosed. After all, how could she in all honesty, properly cross-examine
her own former client?

An Affidavit dated October 24, 2000, sworn to by juror Robert Williams in the Daniel Meehan
case, was discovered in Daniel Meehan’s file (EXHIBIT 55 with Donald Meehan’s June 25,
2008 Affidavit), whereas Mr. Williams states: “Under the instructions given to us by Judge Pat
Clark we sentenced Mr. Meehan to 99 years in prison. However, had a lesser sentence been
available, I would have considered it because I felt that 99 years may have been too harsh a
sentence in this particular case.” It is now obvious that the jurors may not have seen the
“Charge” document or saw a different document than what was filed with the clerk. A 99 year
verdict was filed and recorded one hour and forty minutes later at 3:40 P.M. Here lie more
discrepancies.

According to at least this one juror, the members of the jury may never have seen the “Charge”
document that gave the jury an option to sentence Meehan to not less than five years. However,
with juror Robert Williams’ aforementioned Affidavit, the question is raised whether the jury
even saw this document, and/or for whatever reason that they understood the only verdict
possible was 99 years. This action or inaction adds to the conspiratorial nature of this case. And
all the other jurors should be questioned about this option.

A document has now been discovered as filed by Orange District Clerk Stella Winter at 2:00
P.M., Feb. 5, 1998 (EXHIBIT 56A-B-C with Donald Meehan’s June 25, 2008 Affidavit)
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entitled CHARGE OF THE COURT ON PUNISHMENT, and signed by Judge Pat Clark. It
reads in part: “ You are instructed that the punishment for Murder in this case is confinement in
the penitentiary for a term of not less that (5) five years and not more than ninety-nine (99) years
or Life and the jury may, in its discretion, assess a fine if it chooses in any amount not to exceed
$10,000. Therefore, you will assess the punishment for the defendant at any term of not less than
five (5) years and not more than ninety-nine years of Life confinement…”

CONSTITUTIONAL RIGHTS IMPLICATED

Texas Constitution, Article I Section 13:
Excessive bail shall not be required, nor excessive fines imposed, nor cruel or
unusual punishment inflicted. All courts shall be open, and every person for an
injury done him, in his lands, goods, person or reputation, shall have remedy by
due course of law.
U.S. Constitution, Amendment XIV, Section 1:
All persons born or naturalized in the United States, and subject to the
jurisdiction thereof, are citizens of the United States and of the state wherein they
reside. No state shall make or enforce any law which shall abridge the privileges
or immunities of citizens of the United States; nor shall any state deprive any
person of life, liberty, or property, without due process of law; nor deny to any
person within its jurisdiction the equal protection of the laws.

These constitutional rights have specific applicability with regard to Canon

3(B)(8), which follows.

Judge Clark’s actions appear to have violated at least four provisions of the
Texas Code of Judicial Conduct and the goals set forth in the Preamble:

APPLICABLE CANONS

Preamble

Our legal system is based on the principle that an independent, fair and
competent judiciary will interpret and apply the laws that govern us. The role of
the judiciary is central to American concepts of justice and the rule of law.
Intrinsic to all sections of his Code of Judicial Conduct are the precepts that
judges, individually and collectively, must respect and honor the judicial office
as a public trust and strive to enhance and maintain confidence in our legal
system.. The judge is an arbiter of facts and law for the resolution of disputes and
a highly visible symbol of government under the rule of law.

The Code of Judicial Conduct is not intended as an exhaustive guide for the
conduct of judges. They should also be governed in their judicial and personal
conduct by general ethical standards. The Code is intended, however, to state
basic standards which should govern the conduct of all judges and to provide
guidance to assist judges in establishing and maintaining high standards of
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judicial and personal conduct.

Canon 1: Upholding the integrity and Independence of the Judiciary

An independent and honorable judiciary is indispensable to justice in our
society. A judge should participate in establishing, maintaining and enforcing
high standards of conduct, and should personally observe those standards so
that the integrity and independence of the judiciary is preserved. The provisions
of this Code are to be construed and applied to further that objective.

Canon 2: Avoiding Impropriety and the Appearance of Impropriety in All of the

Judge’s Activities
A. A judge shall comply with the law and should act at all times in a
manner that promotes public confidence in the integrity and impartiality of the
judiciary.

Canon 3: Performing the Duties of Judicial Office Impartially and Diligently

B. Adjudicative Responsibilities
(5) A judge shall perform judicial duties without bias or prejudice.
(8) A judge shall accord to every person who has a legal interest in a
proceeding, or that person’s lawyer, the right to be heard according to law…
(9) A judge should dispose of all judicial matters promptly, efficiently and
fairly.
C. Administrative Responsibilities
(1) A judge should diligently and promptly discharge the judge’s
administrative responsibilities without bias or prejudice and maintain
professional competence in judicial administration, and should cooperate with
other judges and court officials in the administration of court business.

Where honesty or integrity are at issue, a single action can result in a finding of judicial
misconduct. There are a number of cases that refer to Judicial Misconduct. However, since the
Commission’s Complaint instruction directs not to quote cases, we shall merely cite some
quotes:

"It has been said that judicial independence encompasses making mistakes and committing
error, but does not afford protection to judges who repeatedly ignore the law."

“Legal error and judicial misconduct are not mutually exclusive.”

"A single instance of serious, egregious legal error, particularly one involving the denial to
individuals of their basic or fundamental rights, may amount to judicial misconduct."

An emerging pattern of legal errors even though not an egregious legal error nor bad faith should
be labeled misconduct because the continuing pattern of legal error constitutes neglect and
ignorance of governing statutes.
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"legal error by a judge may constitute grounds for a finding of judicial misconduct if the
commission of legal error is founded on bad faith

"a judge who commits legal error which, in addition, clearly and convincingly reflects bad faith,
bias, abuse of authority, disregard for fundamental rights, intentional disregard of the law, or any
purpose other than the faithful discharge of judicial duty is subject to investigation."

Lastly, we wish to add that on information and belief, Gary Wayne Harris is now in Gist Jail for
two years on a Beaumont, Texas 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, and at least once in his “deal” with
Kimbrough in Meehan’s case. In Texas the third felony conviction 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 will approach him, if he hasn’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 Commission on Judicial Conduct 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. Removal
of Judge Patrick Clark seems appropriate.

Thank you for your attention to this matter. We look forward to your favorable response

Sincerely,

_________________________________ ________________________________
Daniel Paul Meehan Donald E. Meehan

And the Undersigned

(list of signers will be attached)