AURIS PROJECT

1006 Wyoming Street Box 1 San Antonio, Texas 78203 Phone: 210-460-0104

January 3, 2016
Chief William McManus
San Antonio Police Department
315 S. Santa Rosa
San Antonio, Texas 78207
Nicolas LaHood, DA
Bexar County District Attorneys Office
Paul Elizondo Tower
101 W. Nueva
San Antonio, Texas 78205
RE: Criminal Complaint and Declaration Against Kristina Combs
Dear Messrs. McManus and Lahood:
As you know, I successfully defended myself against spurious criminal assault charges in Bexar County
Court No. 12, Judge Scott Roberts presiding. On December 8, 2015, the Court was forced to dismiss the
charges against me when the complainant and material witness, practicing attorney Kristina Combs,
refused to show up for trial. The dismissal came more than two years after I was falsely charged with
assaulting and causing bodily injury to Combs. From the beginning, I provided ample proof of my actual
innocence and evidence of criminal offenses committed by Combs to police, prosecutors, and the judge.
The prosecution was defined by a complete absence of probable cause to support the charge against me.
During pretrial proceedings in criminal cause No. 443420, I managed to place on the record
incontrovertible evidence that the complainant Kristina Combs engaged in repeated criminal activity
against the peace and dignity of the State of Texas. Indeed, the habeas corpus record in criminal cause
No. 443420 contains a video recording that shows, among other actions, Combs stealing my personal
items from 1614 Martin Luther King Drive, San Antonio, Bexar County, Texas 78203. She ultimately
stole tens of thousands of dollars from the property, including an entire bookstore, a complete law library,
thousands of dollars of electronics, thousands of dollars in building materials, and thousands of dollars of
furniture, tools, and other inventory. The public record now also contains a report by a court certified
forensic document examiner that exposed the quitclaim deeds Combs used to take control of the property
as fraudulent. It also contains two SAPD police reports that confirm that Combs burglarized two
buildings located at 1614 Martin Luther King Drive on two separate occasions absent writ of possession
even before filing the fraudulent quitclaim deeds. The evidence on the record also makes it clear that
Combs made repeated false statements to police in order to affect my unlawful arrest. In the state of
Texas, breaking and entering a property possessed by another without writ of possession is a serious
crime. The stealing of more than $100,000 of anothers effects, and the use of fraudulent documents to
deprive another of personal assets are felonies.
A few days ago, I discovered what appeared to be the wholesale disposal of the Auris Project bookstore,
more than 2,000 books that Combs stole from 1614 Martin Luther King. Among those items was a
valuable collection of rare Texana books and monographs and other extremely valuable archives, many of
which are irreplaceable. It was a devastating loss. Because I have been the target of persistent attempts on

my life, I could not personally investigate the disposal, although I did make a police report. Similarly, I
have monitored and documented the online sale and disposal of many valuable items stolen from 1614
Martin Luther King.
The video recording shows Combs approaching and striking me. It also demonstrates how Combs and
others assaulted me and illegally pinned me in my car. It also captures Combs viciously kicking my car
door once I retreated to safety, and it clearly confirms that the so-called victim in Cause No. 443420 was
actually the perpetrator. Of course, none of this is news to either of you. What is different is that the
allegations I have been making for years are now supported by unassailable evidence filed in a Texas
court of law. If the rule of law means anything in Bexar County, you will arrest and prosecute Kristina
Combs for her crimes regardless of her associations.
Please consider this a formal complaint and declaration against Kristina Combs for theft, larceny, assault,
battery, fraud, filing fraudulent instruments, and unlawful restraint. The full record in Criminal Cause No.
443420, filed in Bexar County Court No. 12, Judge Scott Roberts presiding, contains more than enough
evidence of criminal activity perpetrated by Combs to give you sufficient probable cause for a lawful
arrest and successful prosecution. Please respond to this letter with some indication of how you intend to
proceed.
I appreciate your prompt attention to this matter.
(DECLARATION REDACTED)

DENISE MCVEA