Part 7 — What the Complaints Will Say
We didn't just write about it. We put our names on formal complaints — and the public money filings back the questions.
When our reporting on Shepherd's Watch got specific, the response wasn't a correction. It was a cease-and-desist — from a lawyer who doesn't exist.
This installment is the paper trail: the formal complaints we will be filing with federal and state authorities over the conduct documented in this series, what each one alleges, and what the public record shows. A filed complaint is not a finding — everywhere below, the register is exact: we alleged X; the agency has not ruled. But the questions will be on the record now, and soon, in front of the people with subpoena power.
The strongest one rests on nothing but their own tax return.
The cleanest complaint requires no witnesses, no disputed accounts, and no inside information. It rests entirely on Shepherd's Watch Foundation's own IRS Form 990-EZ.
We will be filing a complaint with the IRS (Form 13909, Tax-Exempt Organization Complaint) regarding SWF (EIN 81-3142631). What the charity's own most recent public return (FY2025, filed March 30, 2026) shows:
The return lists "Two Wolves Investigations" — a for-profit Texas private-investigations firm — in the CEO/Director compensation line, paid $24,182.
That is the largest single payment the charity reported, in a year it ran a −$49,951 loss and its assets fell about 89% (from roughly $56,000 to roughly $6,000).
One year earlier, the same line paid $4,731 to Kelli Cravens individually. So the reported chief-executive compensation both rose about 411% and shifted from an individual to her for-profit firm — while revenue fell 43%.
Those are figures off the face of a federal filing. Our complaint alleges that this arrangement raises questions of private inurement and excess benefit under IRC §§501(c)(3) and 4958 — that is, that a for-profit company controlled by the charity's own leader was installed as its highest-paid officer while the charity lost money. We do not state that as a proven fact. The IRS has made no determination. We asked the agency — not the reader — to decide what the numbers mean.
Reported chief-executive compensation, FY2024 vs FY2025 (SWF Form 990-EZ, ProPublica).
The fake lawyer
In June 2026, after this reporting began, an email arrived at Project Milk Carton and its CEO from an address (andrewhowardlaw@gmail.com — a free consumer account, no firm, no letterhead, no bar number) signed "Andrew Howard, Counsel for Kelli Cravens." It demanded that PMC delete its public-records reporting about Cravens, Two Wolves Investigations, and Shepherd's Watch Foundation by noon that day.
Two documented facts followed:
1. PMC's CEO replied and asked the sender to provide a bar number, firm name, and address to confirm he was a lawyer. The sender never responded.
2. A licensed Texas attorney actually named Andrew Howard, contacted directly, disclaimed the email and any representation of Kelli Cravens.
In Texas, falsely holding oneself out as a lawyer is a crime (Texas Penal Code §38.122). We filed complaints over this conduct with:
The Texas State Bar (Unauthorized Practice of Law) — regarding the false "attorney" representation.
The Texas DPS Private Security Bureau — because the email was sent expressly "on behalf of" the principal of a Texas-licensed PI business (Two Wolves, license A20467); whether a licensee sent, directed, or benefited from an impersonating communication bears on fitness to hold that license.
The FBI's IC3 and local authorities — regarding the interstate impersonating communication, including a complaint alleging impersonation under §38.122. No charges have been filed.
Important: we do not assert who actually sent that email. Determining the sender's identity is exactly what we asked the authorities — who can compel records a private party cannot — to do. We report the documented conduct: an impersonating legal threat, sent on a licensee's stated behalf, that went silent the moment it was asked to prove itself.
A note on the license: public records indicate Two Wolves' license A20467 is held at the business level. Working under a company's license can be entirely lawful. We make no claim that any individual is personally unlicensed; the Bureau complaint concerns conduct connected to the licensed business, which the Bureau — not this reporter — is positioned to assess.
What each complaint alleges — and its status
If any agency acknowledges, opens, or declines a matter, we will report that honestly — including a decline.
Why we filed at all
Filing a complaint is not an accusation of guilt; it's a request that the people with subpoena power take a look. We put our own names on these because the alternative — publishing serious questions while doing nothing formal about them — would be the less responsible choice. The money questions come straight off a federal return anyone can pull. The impersonation questions come from an email that collapsed the instant it was asked for a bar number. Those are exactly the kinds of things regulators exist to examine, and asking them to is not retaliation — it's the accountability this whole series is about.
Right of reply
Project Milk Carton requested comment from Shepherd's Watch Foundation, Kelli Cravens, and Two Wolves Investigations on the specific complaints and facts in this report. Their responses, or absence of response, are on record.
Sources
IRS Form 990-EZ (FY2025, Filing ID 202640909349200604, filed 3/30/2026) and FY2024, Shepherd's Watch Foundation, EIN 81-3142631 — ProPublica Nonprofit Explorer / IRS.
Complaint copies (IRS 13909; TX State Bar UPL; TX DPS PSB; FBI IC3 / local) — case file SSI-2026-0015.
The "Andrew Howard" email with full technical headers; PMC CEO's unanswered reply; the contemporaneous call log recording the real attorney's disclaimer — case file (preserved, hash-verified).
Texas Penal Code §38.122; IRC §§501(c)(3), 4958.