Combs has been diagnosed with irritable bowel syndrome and is in pain, the motion states. He has been “plagued” by the condition while in jail and has lost weight, according to the court document.
The attorneys say Combs is a lifelong residence of Butler County and a 2014 graduate of Ross High School without a criminal record.
“There is no evidence he is a flight risk,” Pagan wrote in the motion. “Austin suggests that a financial bond with GPS monitoring or home arrest would prove adequate public protection, while protecting his presumption of innocence and permitting him to aid his defense and continue his care.”
After prosecutors responded, Oster indicated he would issue a formal ruling on bond by Dec. 1.
Combs is scheduled to be back in court Dec. 19 for a pre-trial hearing. He admitted to shooting and killing King in the yard of his Chapel Road residence, according to court documents.
According to sheriff’s office investigators, Combs admitted to shooting King “several times with a revolver.”
Video was also obtained, confirming statements by Combs and witnesses, the court documents say.
Combs was taken into custody after deputies were called for a shooting at 11:46 a.m. that early November day, and found King dead outside, according to the sheriff’s office.
Family members called 911 after hearing shots and finding King in the backyard unresponsive and bleeding. A family member told the dispatcher a neighbor had confronted King before about perceived political affiliation.
“My neighbor just shot my dad,” a male tells dispatchers.
The suspect, “just walked back onto his property,” he tells the dispatcher.
According to the son, the neighbor “has come over multiple times making statements. He’s insane.”
The caller’s mother was sobbing in the background, and the dispatcher told them to stay inside and keep the doors locked.
The victim’s wife then told the dispatcher they were cutting grass and working in the yard when she came inside to let the dog out. That’s when she heard gunshots, she said.
“I look in the backyard and that man is walking away from my husband, and my husband is on the ground,” the woman said. “He has come over like four times confronting my husband because he thought he was a Democrat. Why, why … Please, I don’t understand.”
Combs was taken into custody in a Jeep on Ohio 126, west of Chapel Road. Both Combs and his father were in the vehicle.