Due to the Perelman Hatred, with the Jewish Community/Black Community, and most other communities for my so called crimes of kissing a black girl when I was 8 years old, adn angry worldwide mobs riled against me in their racist bigoted hatred against acceptence, and uniting the people: The Judicial system doesn’t apply to me, or one of their racial slurs with LAPD “Kevin’s Kind” because they want segragation, power and control, like Adolf Hitler.

Using Adolf Hitlers views about his next level of psychological warefare called Gas Lighting or Gang Stalking to execute people with Mental Illness Tactics. This is happening with the United States Government, Community Policing, and Pscyhology community with the Perelman family leading the HATE with civilian HATE PUPPETS.

Trying to make things religeous, when they are not.

With some of these death threats like “No relaxing for you nigger” to whip me to death with my family in a worldwide public execution for being like everyone else.

Not only are California courts and judges refusing to provide fair trials covering up their eradication operations, they’ve used police to stalk and harass me for nearly 48 years—all fueled by my own family’s hate, simply because I didn’t fit their mold, think for myself, and am friendly and accepting of all different races and cultures. This started with me, as a child, being attacked for things as innocent as kissing a black girl at summer camp, and turned into them paying people to surveil, gas light, hunt, and essentially try to erase me from existence with mental illness cover up labeling.

The Perelman family with their Jewish and Judicial Power who see themselves above the law. Their warped religious ideologies have made them believe that they are GOD, and can create their own laws and enforce them with their Judicial friends.

Officer Toro with the Perelman family for getting into Studio Photography “If you ever take a picture of a person, I will exercise the law in my own way” Some of the people the Perelman and Silber family have paid off to weasel into my life and STALK and HUNT with his Judicial Family, friends of Dr Ron Perelman. Dr Steve Levinson Gastrologist. Clearly has motive to try to cover up Dr Ron Perelman’s worldwide lies about me, just one of thousands, when he was popping bullet holes in his 300e Mercedes with LAPD, and his .357. Tellling the world it was me behind my back. Mad at me for learning Auto Mechanics and working on cars when I was 16, in 1988. However if his previous anger is about kissing black girls. Then their is no way of making this Pscyhotic family happy with their judicial friends and community stalking groups with the Police trying to cover up their 48 year crimes against me with my family..

However, the real question is, why won’t they let you walk away from their HATRED, and focus on your own life with their mass worldwide conspiracy to commit murder under the pretences of Community Policings? And LAPD with a global commity based Police Force of Fabrications? By stopping me from interacting with others without their hostility based on theri Worldwide Defamation of Character, and stopping me from pursueing a normal life?

Now the system is forcing lawyers with religious and personal agendas on me with the Jewish Perelman family and Arnold Silber my stepfather who flies to Isreal hobnobbing with the Jewish Community while riling them against me in hate. I am being targeted and silenced by zealots like Yisrael Gelb, who protects corrupt attorneys such as Shep Zeberman—my so-called devoutly Jewish defense lawyer who took $50,000 and sabotaged my case, with refusal to defend, or even impeach any witnesses, to expose their stalking groups with Lead Officer Charles Sean Dinse, and his FACEBOOK account, he uses to create vigilante hate mobs, with Chief Michael Moore, to please my family and their network in the courts. Los Angeles Community Policing Programs, designed to STALK, and HUNT, those they don’t like with mental illness labeling cover ups. Judges like Stephan Austin Markus threatened “My next step would be to FORCE you out of your place”, proving this is all about personal HATE and CONSPIRING with CRIMINALS, and theft, not justice with probably about 50 other Constitutional Violations. These are the real Criminals, FAKES and FRAUDS in the Jewish Community who crave POWER and CONTROL, not what GOD intentended. They do not stand for honesty, and truth. They are CRIMINALS. A disgrace to the Bar Association, and a discrace to the Jewish Community. With their HATE labels, and excommunicating someone from the planet earth for kissing a black girl when he was 8 years old. With their Judicial Friends and my SICK PSYCHOTIC family.

Their indirect statements, if you kiss a black girl at 8 years old, or any age, you do not belong amongst humanity. Is that religion? Or ANGRY ENRAGED CULT!? Against humanity. They are the superior race.

My reasonable, legal requests for a new, truly independent appellate lawyer—someone who will actually raise civil rights violations and is not working with the PSYCHOTIC PERELMAN FAMILY, their Judge, Psychology Community, and Police friends on their LAPD HATE Agendas, is not part of a tight nit Jewish Community, is a lawyer for truth and justice, and address ineffective assistance of counsel and the illegal judicial activities—are blocked at every turn. The courts, judges (contrary to Penal Code § 1240 and the California Bar’s ethical rules) are complicit in this campaign, erasing my rights and deliberately ignoring their duty to provide real legal representation. What possible reason would Yisreal Gelb refuse to order the entire transcript, exposing illegal and non-constitutional operations?

Every effort I make for fairness and honest counsel is met with more hate, more gaslighting, more fake labels, and more smear campaigns, and strategically designed to stop me from getting honest help for fair honest arguments—just as my family and their enablers have done since I was eight years old. Now, with the help of Judicial, court-connected figures and organizations, they push lies about me being “anti-Semitic” or unstable—all to justify more discrimination and more abuse. And methods to make their child disappear out of pure hared and rage for him.

The law is clear: I am entitled to unbiased, honest counsel. I have never received it. This is a campaign of legal and judicial misconduct

Lawyers who participate in these kinds of unethical and illegal acts—sabotaging their own clients, conspiring with outside parties, or covering up judicial and police abuse—can and should face severe disciplinary action. Under California law and State Bar rules, they may be disbarred, suspended, or even charged criminally for violations like fraud, obstruction of justice, perjury, and conspiracy (see California Business & Professions Code § 6106 and Penal Code § 182). These penalties exist to protect the public from corrupt attorneys who betray the trust of those they are sworn to defend.

2001, while LAPD, Rodie Morales, And Mike Huntley were paid off to hunt me to have me eradicated by the Perelman, and Silber family, while Rodie Morales with trying to plant a trashbag of LAPD marijuana in my house to try to frame me to look like a drug dealer and set me up.

Mike Huntley and LAPD’s death threats “We are using the Judicial System Against you”, “Have a good life now”, “You had better live a careful life, “World of Paranoia”

http://www.KevinPerelmanTarget.com

http://www.TheHateCage.com

I’m forced to submit these motions for my safety, and to help the public understand what’s happening behind the scenes in my appeal process. And they slowly try to push me towards non-existance or in a cage.

After requesting new legal representation due to a clear conflict of interest, I discovered that my appointed lawyer, Rabbi Gelb, submitted a flawed and insufficient opening brief without addressing the issues I raised. My request for a new attorney went through the California Appellate Project (CAP)—the organization responsible for assigning public defenders and relaying defendants’ concerns to the courts and attorneys. CAP is supposed to ensure that defendants receive fair and conflict-free representation.

Instead, the process was quietly derailed through what I believe to be manipulation of paperwork and procedural games designed to undermine my defense—something I’ve seen consistently with LAPD’s rogue policing and the misuse of community policing programs. These operations are empowering groups of civilians to act with impunity, committing crimes under the protection of law enforcement and the courts.

This isn’t just about one motion—it’s about a pattern of coordinated judicial and law enforcement misconduct. I’ve been systematically denied the right to a fair trial and honest representation. What’s being exposed here is a conspiracy under Penal Code §182, involving deliberate obstruction, corruption, and an agenda not based on justice or facts, but on silencing and eradicating individuals they target.

This motion is one of many documents I’ve had to write myself—just to be heard. And even then, the system works overtime to bury the truth.

COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT, DIVISION FOUR

Case No: B343120

The People,

Plaintiff and Respondent,

v.

Kevin Perelman,

Defendant and Appellant.

MOTION FOR LEAVE TO FILE NEW OPENING BRIEF DUE TO REPLACEMENT OF COUNSEL AND INCOMPLETE RECORD IN PRIOR BRIEFING

To the Honorable Justices of the California Court of Appeal, Second Appellate District, Division Four:

Kevin Perelman (“Appellant”) respectfully requests leave of the Court to file a new opening brief, and states as follows:

1. This case presents factual and legal complexities that require careful analysis and a thorough presentation of all relevant issues.
   
   2. Appellant’s former counsel, Rabbi (Mr.) Gelb, filed an opening brief on October 13, 2025, after the submission of and prior to a decision regarding the appointment of new counsel and before the Court’s review of a then-pending motion related to representation.
   
   3. Appellant respectfully submits that prior counsel did not fully understand, nor invest the necessary time and attention to, the particular complexities and nuances of this case.
   
   4. Moreover, prior counsel did not have access to the full set of court transcripts; he possessed only those covering the trial days and sentencing proceedings, but not the full record of pretrial hearings or other relevant proceedings. As a result, the original opening brief could not accurately or fully address all legal and factual issues pertinent to this appeal.
   
   5. Appellant is now proceeding in propria persona (“pro per”) and, after reviewing prior submissions and the limited record previously available, believes that the interests of justice require the opportunity to submit a more accurate and complete opening brief—either on their own behalf or through new counsel who will devote adequate time to understanding the entire case.
   
   6. The timing of the opening brief—filed before the issue of representation was—further supports the need for this request.
   
   7. Appellant understands that respondent’s brief may have already been filed. However, given these circumstances, Appellant respectfully asks the Court to grant leave to file a new or supplemental opening brief. Appellant also requests adequate time to thoroughly review the complete record and, if new counsel is appointed, to confer meaningfully with counsel in order to ensure that all relevant issues are fully and accurately presented to the Court. Appellant is prepared to comply with any reasonable briefing schedule the Court may deem appropriate to ensure fairness for all parties.
2. WHEREFORE, Appellant respectfully requests that this Court grant leave to file a new or supplemental opening brief, preferably with newly appointed counsel who has access to the complete record, or, if necessary, in propria persona; and set an appropriate schedule for its submission.

Dated: 10/21/2025

Respectfully submitted,

Kevin Perelman

26500 Agoura Rd, Ste 102

Calabasas, CA 91302

312-259-3686

Appellant, in Pro Per

These documents demonstrate that my request for new counsel was formally submitted before the opening brief was filed. Despite this, attorney Yisrael Gelb, who was assigned by the California Appellate Project (CAP), went ahead and filed an opening brief that ignored key issues in the case and failed to include critical transcripts.

Among those missing transcripts are portions of the record showing judicial misconduct — including statements made by Judge Steven Marcus of the Van Nuys Courthouse, such as “My next step would be to force you out of your place.”
This language, in context, raises serious concerns about bias and abuse of judicial authority.

My concern is that this was not simply an oversight, but part of a broader pattern of procedural obstruction and ineffective assistance of counsel, where defense attorneys with clear conflicts of interest are repeatedly assigned to my cases. CAP’s role is to ensure fair, conflict‑free legal representation, yet they assigned an appellate lawyer with limited experience, who disregarded my prior filings and failed to pursue the misconduct evidence already in the record.

These issues appear to be connected to a long‑running pattern of discrediting and isolating me through defamation, false labels, and psychological manipulation — a campaign that began when I was a child and continues today. The current legal process reflects that same systemic bias: rather than evaluating facts and evidence, the system continues to recycle the same false narratives to justify misconduct and silence me.

This is not simply about one appeal; it is about a pattern of judicial and institutional behavior that undermines constitutional rights, fair trials, and the rule of law.

Kevin Perelman

26500 Agoura Rd, Ste 102

Calabasas, CA 91302

312-259-3686

10/17/2025

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA SECOND APPELLATE DISTRICT, DIVISION FOUR

The People of the State of California, Plaintiff and Respondent,

v.

Kevin Perelman,

Defendant and Appellant.

Case No. B343120

MOTION FOR APPOINTMENT OF NEW COUNSEL

(REQUEST FOR SUBSTITUTION OF APPOINTED ATTORNEY)

TO THE HONORABLE COURT OF APPEAL, SECOND APPELLATE DISTRICT:

Defendant and Appellant Kevin Perelman respectfully moves this Court for the appointment of new appellate counsel. This motion is based on the following grounds:

Right to Effective, Conflict-Free Counsel:

Pursuant to the Sixth Amendment of the United States Constitution and Article I, Section 15 of the California Constitution, “In all criminal prosecutions, the accused shall enjoy the right…to have the Assistance of Counsel for his defence.”

California law requires that appointed counsel must provide effective and conflict-free assistance at all critical stages of the proceedings. (People v. Marsden (1970) 2 Cal.3d 118; California Penal Code § G87.2.)

Grounds for Substitution:

A defendant is entitled to new counsel if there is a conflict of interest, a breakdown in the attorney-client relationship, ineffective assistance, or loss of trust or confidence in current counsel. (See Marsden, supra; People v. Smith (1993) 6 Cal.4th 684, 696; People v.

Ortiz (1990) 51 Cal.3d 975.)

Specific Basis for Request:

Appellant has experienced a breakdown in the attorney-client relationship, “failure to investigate/appellate issues, conflicts of interest, lack of communication, and loss of trust”.

See Attachment Letter:

Request for Hearing:

Appellant requests that the Court conduct a hearing to consider this request for substitution of counsel, as required by People v. Marsden, supra.

WHEREFORE, for the reasons stated above, Appellant respectfully requests:

• • That the Court grant this motion,
  • That new appellate counsel be appointed, and
  • For any other relief the Court deems just and proper. Respectfully submitted,

Kevin Perelman, Appellant

Legal Authority

• • Sixth Amendment, U.S. Constitution; Cal. Const., Art. I, § 15
  • Cal. Penal Code §§ 987, 987.2
  • People v. Marsden (1970) 2 Cal.3d 118
  • People v. Smith (1993) 6 Cal.4th 684, 696–697
  • People v. Ortiz (1990) 51 Cal.3d 975

Attachment 1

CAP-LA Attorney/Staff Directory, October 2025 printout

Attachment 2

Email from Rick Lennon (CAP-LA), September 14, 2025

Attachment 3

Appellate court docket screenshots (“replace appointed counsel”)

Attachment 4

Proof of Service Date 10/20/2025 instead of 10/15/2025 inconsistencies

Attachment 1

criminal cases (now including 3PY03498 and 7VW04099)

Van Nuys Courthouse Cases with Judicial Misconduct: criminal cases:

3PY03498

7VW04099

Attachment 6

Prior request for reassignment of appellate counsel (August 4, 2025)

To

California Appellate Project

Phone: Phone: (213) 243-0300

Fax: (213) 243-0303

August 4, 2025

Appellant

26500 Agoura Rd, STE 102

Calabasas, Ca 91302

312-259-3686

Kevin@KevinPerelman.com

Email:Capdocs@lacap.com AppellateBranch@pubdef.lacounty.gov

Adress: 520 South Grand Avenue, 4th Floor Los Angeles, CA 90071

To Whom It May Concern:

The People v. Kevin Perelman, Case No. B343120 Court of Appeal, Second Appellate District, Division Four

Dear Supervising Attorney,

I am writing to formally request the reassignment of new appellate counsel in my case, The People v. Kevin Perelman, Case No. B343120, currently before the Court of Appeal, Second Appellate District, Division Four.

I have serious concerns about a potential conflict of interest that could affect my representation. While my current appointed appellate attorney has not acknowledged any conflict, I feel there is a strong likelihood of one due to community affiliations and the circumstances of my case. Both my previous trial attorney and the current appellate attorney are members of the same small, close- knit community (the Jewish community), and my current appellate attorney is also a Rabbi. I am concerned these community connections may create both the appearance and reality of divided loyalty, and possibly an unwillingness to fully pursue claims involving another member of the same community.

Additionally, I am concerned about my appointed appellate attorney’s limited experience (approximately two years since passing the bar), which I believe is insufficient for a case of this seriousness and complexity. As an inexperienced lawyer, he may not possess the necessary knowledge or familiarity with habeas corpus proceedings. He has told me directly that he believes he is limited to what is included in the trial transcripts and docket, even though filing a writ of habeas corpus is often necessary to address ineffective assistance of counsel based on facts outside the transcript and docket.

It is especially important to note that my case may also involve significant judicial and prosecutorial misconduct. My concerns include, but are not limited to, fraudulent police reports, improper investigative practices, potential bias or unfair treatment from both the prosecution and the trial court, and witnesses conspiring with police in illegal operations. I am deeply concerned that these issues have substantially impacted the integrity and fairness of my trial, and that they warrant careful and impartial review on appeal. I believe my current appellate counsel is not adequately positioned, either in terms of experience or independence, to thoroughly investigate and argue these matters, especially where those issues involve or are intertwined with claims of ineffective assistance of counsel.

For these reasons, I respectfully request that a new appellate attorney —one with no prior professional or personal association with my previous legal counsel, not a member of the same religious or social network, and who is highly experienced with both direct appeals and habeas corpus claims—be assigned to handle my appeal. It is critically important to me that my appellate representation is impartial and fully qualified to pursue all necessary legal remedies, including direct challenges to judicial or prosecutorial misconduct and the involvement of witnesses in illegal conduct.

I trust that you will carefully review my concerns and take timely action to ensure fair representation as required by law. Thank you for your attention to this urgent and sensitive matter.

Sincerely,

Kevin Perelman

Kevin Perelman

Attachment 7

Statement of Ineffective Assistance of Counsel and Petition for Writ of Habeas Corpus

To

California Appellate Project

Phone: Phone: (213) 243-0300

Fax: (213) 243-0303

Email:Capdocs@lacap.com AppellateBranch@pubdef.lacounty.gov Adress: 520 South Grand Avenue, 4th Floor Los Angeles, CA 90071

To Whom It May Concern:

The People v. Kevin Perelman, Case No. B343120 Court of Appeal, Second Appellate District, Division Four

Petition for Writ of Habeas Corpus

Ground: Ineffective Assistance of Counsel — Presentation of New and Extrinsic Evidence

1. Petitioner’s Claim: Ineffective Assistance of Counsel

Petitioner, Kevin Perelman, respectfully seeks habeas corpus relief based on egregious ineffective assistance of counsel by Shep Zebberman, as demonstrated by facts both in and outside the trial record. This claim is supported by the following:

1. Legal Standard (Strickland v. Washington) Relief is warranted when:
   1. Counsel’s performance was constitutionally deficient;
   2. There is a reasonable probability that, but for counsel’s unprofessional errors, the result would have been different.
2. Statement of Facts C New Extrinsic Evidence

Discriminatory and Prejudicial Conduct

• • • Shep Zebberman made prejudiced statements and failed to advocate for me due to personal and community bias, as described in my declaration and corroborated by third-party witnesses and community records.

Failure to Investigate, Prepare and Present Defense

• • • Did not review or present extensive video evidence of mobbing, vandalism, and ongoing harassment in conspiring methods and events with LAPD.
    • Refused to meet with me to discuss my side of events, relying solely on prosecution evidence.

Failure to Investigate or Call Available Witnesses

• • • Never investigated, interviewed, or subpoenaed witnesses who could have testified on my behalf, including:
• Eyewitnesses to harassment, vandalism, and provocation;
• Neighbors and community members familiar with false allegations by Officer Dinse, Terrance Scroggins, Pedram Espinoza, and others;
• Victims of Officer Dinse’s similar misconduct (e.g., federal lawsuit by Rex Schillenberger);
• Experts in police procedure and community mobbing.
  • Failure to hire or consult with any private investigator who could have interviewed witnesses, gathered additional exculpatory statements, or tracked social media campaigns against me.
  • Evidence: Declarations from available witnesses, statements from those never contacted by defense, my own sworn declaration, investigator reports (if available), and a list of potential witnesses with what their testimony would have shown.
  • Failure to introduce events of police harassments, intimidation, as well as witness harassment, intimidation, before and during the trial.

Failure to File Key Motions and Argue Self-Defense

• • • Did not file a Pitchess motion against Officer Dinse, despite his documented history of similar misconduct.
    • Refused to argue self-defense even with documentary/video evidence of years-long provocation by community and police.
    • Did not challenge fabricated restitution claims or expose documented blackmail efforts by prosecution witnesses. Working with their friends in the court house to pose as FBI agents for intimidation.

Conflict of Interest s Coercion Toward Insanity Plea

• • • Prioritized relationships with trial judges over client defense.
    • Pressured me to accept Not Guilty by Reason of Insanity (NGI) without legal/medical basis.

Failure to Seek Change of Venue or Protect Against Community Harassment

• • • Ignored repeated, documented attempts by Officer Dinse and neighborhood watch to incite community bias, including via Facebook and public statements.
    • Did not move to change venue despite mass prejudice, nor did he advise or assist with seeking restraining orders against harassers.

Failure to Impeach Prosecution Witnesses

• • • Did not challenge (impeach) perjured or contradictory testimony from key witnesses, and did not present readily available impeachment material (videos, letters, reports).

Failure to Protect Defendant from Direct Courtroom Intimidation

• • • Did not object or seek mistrial when individuals impersonating FBI agents appeared in the courtroom with Prosecutor Orbelli to intimidate me in the presence of the judge and jury—egregious misconduct designed to prejudice my defense, create an unfair environment, and reinforce false government narratives.
    • Failed to raise the issue of prosecutorial collusion with these individuals and did not seek judicial intervention or police report to expose this unlawful intimidation tactic.
    • Evidence: My declaration, affidavits from anyone who witnessed or heard about the “FBI” presence, court security reports, and any correspondence with court staff about these incidents.

G. Additional Examples of Evidence Outside the Trial Record

• Newly available police records or Bar complaints showing patterns of misconduct not included in trial evidence.
• Social media posts by Officer Dinse or others, including deleted/archived content recovered through subpoenas.
• Expert opinions now available but not sought by defense (e.g., on police procedure, mobbing, prejudice).

1. Prejudice: Strickland Standard Satisfied Because of the above errors:

• The jury never heard or saw critical exculpatory evidence or witness testimony that

would have undermined the prosecution’s case.

• Lack of a private investigator, lack of witness interviews, and failure to object to intimidation fundamentally denied me a fair trial.
• The outcome would likely have been different had defense counsel met even minimal professional standards.

1. Prayer for Relief and Request for Evidentiary Hearing

Petitioner respectfully requests:

• 1. An order to show cause and/or evidentiary hearing to receive this new, extrinsic evidence.
  2. Vacation of conviction and/or outright dismissal due to cumulative constitutional error.

1. Evidence to be Attached (Example)

• Declaration of Kevin Perelman (listing all witnesses I requested or identified, complaints re: FBI impersonators, failure to investigate)
• Declarations/affidavits from uninvestigated witnesses, neighbors, and potential experts
• Affidavit from (or record of attempted contact with) a private investigator, if available
• Videos and audio not introduced at trial
• Screenshots/archived copies of relevant Facebook/social posts
• Security/court incident reports regarding presence of FBI agents or intimidation efforts
• Insurance, restitution, and any financial records relating to blackmail/extortion claims
• Copies of relevant Bar complaints, police records, or civil complaints

Attachment 8

Trial Judicial Misconduct – Notes

To

California Appellate Project

Phone: Phone: (213) 243-0300

Fax: (213) 243-0303

Email:Capdocs@lacap.com AppellateBranch@pubdef.lacounty.gov Adress: 520 South Grand Avenue, 4th Floor Los Angeles, CA 90071

To Whom It May Concern:

The People v. Kevin Perelman, Case No. B343120 Court of Appeal, Second Appellate District, Division Four

Ineffective Assistance of Counsel and courtroom misconduct – Shep Zebberman Specific Accusations:

• Discriminatory and Prejudicial Comments
• Sheps Statement to me, right before the verdict “You might get away with this” Showing from day one, he was acting as a judge, not a Lawyer. And was never going to represent me fairly and was involved in a conspiracy to lock me away no matter how innocent. No matter how much proof. He wasn’t even going to try to prove my innocence.
• Everything asked he give an opposite answer, and disinformation, showing anger. I asked about change of venue. like change of venue, he lied stating their was not grounds for. While was friends with a lot of the Judges. Being provoked and harassed by witness Terrance Scroggins during trial. Would not help with filing restraining orders or use the information to show in the court at any time that Terrance was always the aggressor or impeach the witnesses properly jumping from lawyer to lawyer.

– Penal Code § 147: Willful deprivation of a client’s rights

Failure to Investigate/Prepare/Defend

• Did not review Kevin’s exculpatory video evidence or ask for Kevin’s version of events. – Relied on fabricated reports and prosecution narrative. – Penal Code § 1054.G: Failure to seek or present exculpatory evidence

Failure to File Key Motions

• Judge Dohi, refused to file Pitchess motion for LAPD Officer Charles Sean Dinse, despite Dinse’s federal lawsuits for similar behavior. – Would not request change of venue or move for mistrial, nor file dismissal. Even with the events happening in the court room – Penal Code § 1054.5: Withholding of motions/evidence

Conflict of Interest

• Admitted being friends with Judge Gregory A. Dohi and Judge Stephen Marcus, failed to zealously advocate for client. – Potentially took $50,000 under false pretenses (with influence from Arnold Silber, Kevin’s stepfather). – Penal Code § 182(a)(5): Conspiracy to obstruct justice

Coercion Toward Insanity Plea (NGI)

• Tried to pressure client to plead NGI to “get you out of this,” abusing attorney’s power/trust. Stating “I can get you out of this” I know some Psychology People – Business s Professions Code § 6068: Duty to act with honesty and loyalty

Refusal to Provide Self-Defense Argument

• Refused to present documented mobbing/stalking history; said self-defense not possible for vandalism despite clear evidence of gangstalking and conspiracy amongst mass stalking groups with LAPD with an Agenda to setup or frame the defendant. – Penal Code § 6G2-6G4: Legitimacy of self-defense argument

Judicial Corruption s Misconduct Specific Accusations:

• • Bias and Prejudice
• Judge Stephen Marcus: “I’ll squeeze you out of your place.”
• Judge Gregory A. Dohi: Fabricated mental health diagnoses, belittled and intimidated defendant (“Come on down!”) treating court rooms and trials like fun game shows, denied defense motions for Pitchess; colluded in systemic prejudice.
• Penal Code § G6 s G6.5: Judicial officers acting corruptly, maliciously, or with conflict of interest

Van Nuys Court Reporter who owns property adjoining my wall Misconduct –

Debbie Wollman

• Spread false rumors about Kevin’s mental health to court staff and judges; owned property adjoining defendant (conflict of interest). – Omitted critical exculpatory phrases from transcripts (e.g., “Every Miata is modified”). – Penal Code § 134: Preparing false evidence (tampered transcript) – Penal Code § 182: Conspiracy

Police Corruption – Officer Charles Sean Dinse Specific Accusations:

• • History of Lawsuits and Misconduct
• Used Facebook to incite neighborhood harassment against Kevin; earlier federally sued by Rex Schillenberger.
• Publicly posted “How do we FORCE people into mental facilities,” inciting community intimidation/hate/Stalking groups.
• Penal Code § 182: Conspiracy to violate civil rights
• Penal Code § 135: Destroying/concealing evidence

Fabrication of Claims and Evidence

• Lied about Kevin following him with Prosecutor Orbell to use as amo for increased sentencing, staged incidents to provoke legal trouble. – Seized art computer (falsely called a “hard drive”), made misleading claims about data. – Penal Code § 118: Perjury – Penal Code § 141: Planting/tampering with evidence

Intimidation and Collusion

• Orchestrated use of “fake FBI agents” to intimidate Kevin in courtroom right before trial day. – Colluded with Prosecutors Lisa Orbelli and Detective Ruiz, and Charles Sean Dinse.
• Penal Code § 136.1: Witness/victim intimidation – Penal Code § 182: Conspiracy

Witness and Community Misconduct

Specific Accusations:

• • Terrance Scroggins (Neighbor/Witness):
• Engaged in continuous harassment/provocation before and during the trial(240+ videos), staged vandalisms with neighbors, Provokings, submitted false restitution claims (colluded with USAA Insurance to repaint entire car, then sought extra $5,000 after USAA paid for repairs).
• Left blackmail threats in writing demanding DIRECT restitution money.
• Penal Code § 518: Extortion
• Penal Code § 118: Perjury

Pedram Espinoza (Neighbor/Witness):

• Provided knowingly false testimony about his time at the property and his encounters with Kevin. – Penal Code § 118: Perjury. No impeaching the witness with Pedram on video

stating I’m not allowed at my townhouse complex. Or that I take pictures of kids. Showing he’s defaming my name and has motive to get rid of me. Shep kept the argument in the context to make it look like I was loitering around his house, in the common areas of our complex. A Juror had to ask the Judge how long I lived their he picked up one the one sided stories.

Community Members (“Yosi,” Jason Ryan Fishman, etc.):

• Participated in organized surveillance/harassment; repeated slander (“not a real Jew,” “mentally ill”), acted at direction of Officer Dinse and neighborhood watch. – Penal Code §

653.2: Electronic/cyber harassment – Penal Code § 182: Conspiracy to harass. Showing linked events within the Jewish Community.

Prosecutorial Misconduct Specific Accusations:

• Lisa Orbelli s Detective Ruiz (Prosecutors):
• Collaborated with police and witnesses to create “incidents” for prosecution; made false claims and permitted intimidation tactics in and around the courthouse.
• Permitted/introduced false evidence, allowed staged intimidation (fake FBI agents and courthouse staff).
• Penal Code § 118: Subornation of perjury
• Penal Code § 182: Conspiracy
• Penal Code § G6.5: Misconduct by officers of the court

Transcript, Records, and Restitution Tampering Specific Accusations:

• • Omitted or altered evidence/testimony in trial transcripts (Debbie Wollman).
  • Docket/minute orders contained unexplained errors or clerical manipulation (split sentence, “no probation” issues), possibly at the direction of corrupt clerks and neighbor/court reporter Debbie Wollman.
  • Restitution awarded based on fraudulent insurance claims and blackmail tactics (Terrance Scroggins).
  • Penal Code § 134: Preparing false documentary evidence
  • Penal Code § 115: Filing false instruments

Overarching Constitutional and Civil Rights Violations Specific Accusations:

• • Constitutional:
• Denial of due process (U.S. Const. Amend. XIV)
• Denial of effective assistance/counsel (U.S. Const. Amend. VI; Strickland v. Washington)
• Denial of fair trial and equal protection (California Const. Art. I, §§ 7, 15)

Pattern of Systemic Government Abuse:

• Collusion among judges, defense, prosecutors, police, and community.
• Tampering, intimidation, and long-term targeting that makes fair retrial impossible.
• Penal Code § 182: Criminal conspiracy
• Civil Remedies: 42 U.S.C. § 1983 (federal civil rights suit for deprivation of rights under color of law)

Judicial Corruption—Grounds for Dismissal Overlooked

• • Repeated Judicial Bias:
• Judge Stephen Marcus made overtly hostile comments toward Defendant (“I’ll squeeze you out of your place”), demonstrating clear personal animosity and prejudice contrary to impartial adjudication required by law.
• Judge Gregory Dohi fabricated “mental illness” labels for Defendant with no clinical basis, belittled Defendant during proceedings, and denied valid defense motions (e.g., Pitchess motion for Officer Dinse), demonstrating pattern of prejudiced rulings.

Legal Basis: Judicial bias and partial are grounds for mistrial or dismissal:

• *Caperton v. A.T. Massey Coal Co.*, 556 U.S. 868 (2009) (extreme judicial bias may violate due process).
• Cal. Penal Code § 96, § 96.5 (corrupt conduct by judicial officers).

Court Reporter Misconduct s Transcript Tampering:

• Debbie Wollman, with a direct conflict of interest, fabricated negative mental health rumors about Defendant to judges and staff, and altered the official record (omitting exculpatory testimony such as “Every Miata is modified”). Legal Basis: Cal. Penal Code § 134 (preparing false evidence), § 182 (conspiracy to pervert justice).

Police Officer Corruption—Grounds for Dismissal Overlooked

• • Officer Charles Sean Dinse’s Documented Corruption:
• Used his Facebook account to incite community mobbing (“How do we FORCE people into mental facilities”), was previously federally sued for similar actions.
• Lied under oath about Defendant following him with Prosecutor Orbelli for increased

sentencing, fabricated incidents, and seized Defendant’s computer misrepresenting both

its contents and evidentiary value.

• Regularly engaged in provocation and intimidation designed to escalate Defendant’s legal peril.

Legal Basis:

• Cal. Penal Code § 118 (perjury), § 141 (evidence tampering), § 182 (conspiracy), § 147 (officials depriving rights).
• Cal. Evidence Code § 1043 et seq. (Pitchess motion—officer history of dishonesty/abuse is grounds for discovery, impeachment, and, where egregious, dismissal).

Prosecutorial Misconduct—Compelling Grounds for Dismissal Ignored

• • Fabrication, Coll, and Use of False Evidence:
• Prosecutors Lisa Orbelli and Detective Ruiz collaborated with Dinse, Scroggins and others, knowingly presenting false or uninvestigated claims to the court.
• Prosecutors enabled and facilitated courtroom intimidation—including the appearance of people posing as FBI agents during trial—creating an atmosphere of threat and unlawfulness.
• Prosecutors injected irrelevant hearsay and prejudicial evidence into the record, repeatedly straying from the charges to paint Defendant as dangerous or unstable, manipulating judicial perception and deliberation.

Legal Basis:

• *People v. Batts* (2003) 30 Cal.4th 660, 693 (dismissal appropriate in egregious government misconduct).
• Cal. Penal Code § 118 (subornation of perjury), § 182 (conspiracy), § 96.5 (prosecutorial misconduct).

Admission of Hearsay/Irrelevant Allegations:

• Prosecutors repeatedly introduced and relied on one sided prejudicial statements and hearsay incidents—statements, rumors, alleged threats, and unrelated community disputes—irrelevant to the charged offenses, used solely to inflame and manipulate the judge and jury. – Defense counsel failed to object or move to strike these prejudicial and improper references, compounding the miscarriage of justice. Legal Basis: – Cal. Evidence Code § 1200 (hearsay inadmissibility), – *People v. Fuiava* (2012) 53 Cal.4th 622 (admission of repeated, irrelevant misconduct evidence is reversible error).

Cumulative Misconduct Clearly Justified Dismissal

• • Pattern of Collusion:
• Combined judicial, police, and prosecutorial bias, evidenced by intimidation, tampering, and fabrication, destroyed any pretense of fair trial.
• Egregious conduct rises to the constitutional standard where “the only appropriate

remedy is dismissal,” as retrial would merely replicate injustice.

Missed Opportunities for Relief:

• At each stage—pretrial (based on evidence fabrication/transcript tampering), during trial (judicial bias, police perjury, prosecutorial hearsay, intimidation), and post-trial (restoration of rights, clerical errors)—counsel declined to move for dismissal.

Grounds for Dismissal (Relief Requested):

• • Cumulative due process violations.
  • Systemic government misconduct and collusion.
  • Prejudice so severe retrial would be unjust and constitutionally insufficient.
  • Legal authorities: US and California Constitution, People v. Batts (2003), Strickland. Washington (4), Caperton v. Massey (2009), Penal Code §§ 96, 96.5, 147, 182.

I

am requesting an extension of time to file a new or supplemental opening brief because the appellate counsel originally assigned to me, Attorney and Rabbi, Yisrael Gelb, submitted a vague and incomplete brief that failed to address the constitutional and judicial misconduct central to my case.

1. Background and Procedural Timeline

• October 13 2025: Attorney Gelb submitted an opening brief before the court.
• October 15 2025: A formal request for new counsel was filed with the California Appellate Project (CAP) due to conflicts of interest and ineffective assistance.

Despite this pending request, counsel filed a brief that omitted crucial information and minimized the seriousness of judicial and procedural misconduct that occurred at trial. No significant transcripts exposing judicial bias or constitutional violations were ordered or referenced. Example Judge Marcus showing agenda vilating all constitutionality “My next move would be to FORCE you out of your place” Which should be on transcript, unless court reporter who owned her empty property for 20 years adjoining my wall is removing things with her judicial court reporter friends. Who is on video stating that I have to admit to having schitzofrenia.

2. Grounds for the Request

The brief submitted by appellate counsel:

• Excluded evidence of judicial misconduct, including statements from Judge Steven Marcus of the Van Nuys Courthouse indicating improper motives (“My next move would be to force you out of your place”).
• Ignored the broader context of coordinated harassment and procedural corruption that has followed me for years.
• Failed to raise ineffective assistance of counsel or any discussion of my prior counsel’s conflicts and omissions.
• Omitted a request for a Writ of Habeas Corpus or any acknowledgment of material facts supporting my innocence.

3. Pattern of Misconduct and Systemic Bias

This appeal is not an isolated issue—it is part of a continuing pattern in which defense attorneys, court personnel, and outside actors have acted in concert to suppress exculpatory evidence and distort proceedings. The record shows repeated failures to present or even request critical trial transcripts that would expose procedural irregularities, bias, and retaliation.

4. Relief Requested

Given these circumstances, I respectfully request:

1. An extension of time to file a new or supplemental opening brief.
2. Authorization to obtain and include all relevant trial transcripts and supporting documents omitted from the current record.
3. A review of the California Appellate Project’s handling of my request for conflict‑free counsel.

5. Purpose

This motion is necessary to correct the record, expose procedural corruption, and ensure that my appeal reflects the truth of what occurred in court. The integrity of the appellate process—and my right to a fair hearing—depend on allowing the submission of a complete, accurate, and honest opening brief.

COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT, DIVISION FOUR

Case No: B343120

The People,

Plaintiff and Respondent,

v.

Kevin Perelman,

Defendant and Appellant.

Request for Extension of Time to File New or Supplemental Opening Brief

To the Honorable Justices of the California Court of Appeal, Second Appellate District, Division Four:

Kevin Perelman (“Appellant”) respectfully requests an extension of time to file a new or supplemental opening brief in this case. In support of this request, Appellant states as follows:

1. Appellant’s former counsel, Rabbi (Mr.) Gelb, filed an opening brief on October 13, 2025, before the Court ruled on the pending issue of representation and prior to the appointment of new counsel.

2. Prior counsel did not have access to the complete set of court transcripts, relying only on trial and sentencing transcripts, and was therefore unable to address all legal and factual issues pertinent to the appeal.

3. Appellant is now proceeding in propria persona (“pro per”) and has moved for the appointment of new counsel who will have adequate time and access to the full record.

4. In order to ensure a fair opportunity to prepare and present a complete and thorough opening brief, Appellant respectfully requests an extension of time both to review the entire record and, if counsel is appointed, to meaningfully confer with new counsel about the case.

5. This request is made in good faith and is not for purposes of delay, but to ensure the interests of justice and fairness to all parties.

6. Appellant is prepared to comply with any reasonable briefing schedule deemed appropriate by the Court.

WHEREFORE, Appellant respectfully requests that the Court an extension of time to file a new or supplemental opening brief for 120 days from the date of the Court’s order, or such other reasonable date as the Court deems appropriate, to allow for the appointment of new counsel, review and receipt of the complete record, and meaningful preparation of the brief. Appellant also requests that the Court set an appropriate briefing schedule thereafter.

Dated: 10/21/2025

Respectfully submitted,

Kevin Perelman

26500 Agoura Rd, Ste 102

Calabasas, CA 91302

312-259-3686

Appellant, in Pro Per

Prior Illegal Arrests and Evidence of Coordinated Judicial Entrapment

The events in my current case are not isolated—they follow a longstanding pattern of judicial intimidation, deceptive legal tactics, and abuse of due process, as demonstrated by incidents going back to at least 2017 and 2013.

In one such case, attorney Richard Barnwell, an African-American lawyer from the Johnny Cochran Law Firm representing me, told me to wait outside the courtroom during check-in. He later informed me the case had been dismissed—only for me to find out later that he never officially checked me in, leading to a warrant being issued. This was after I had paid him for representation. This type of bait-and-switch behavior not only sabotaged my legal standing but also reveals how almost all, defense attorneys I’ve hired, and even public defenders, have acted in coordination with systemic abuse.

This also reflects broader hostility from certain communities—including a misplaced narrative that traces back to an incident when I was eight years old, after kissing a Black girl. Instead of seeing childhood innocence, this moment was used as a bizarre origin point for what has evolved into widespread social and legal targeting, magnified by family betrayal and cultural manipulation. Which stems from my own family.

The hostility escalated with threats from individuals like Mike Huntley, who openly stated:

• “We are using the judicial system against you,”
• “You’d better live a careful life,” and
• “Have a good life now.”
• Singing “World of Paranoia”

While placing materials on my desk in front of me, referencing psychological warfare operations such as How to make people in South Korea mentally ill to control or eradicate, suggesting these were not jokes or pranks but part of a systematic psychological control framework used to target and destabilize individuals. These statements and materials demonstrate clear motive and premeditation, showing that this has never been about justice—it’s about erasure.

What I have since uncovered is that this operation includes a network of government, police, civilian vigilantes, and psychology professionals which is now worldwide, with roots going back to when I was five years old. What began with minor or fabricated incidents has become a global abuse campaign, coordinated across legal, community, and family structures, to discredit and destroy me under the pretext of mental health and legal justification.

What dirty little secrets, in the government are they trying to protect and cover up? What are they doing to people, especially children that they are “Afraid Of”?

Court of Appeal of the State of California

Second Appellate District, Division Four

Case No. B343120

The People v. Kevin Perelman

MOTION TO AUGMENT THE RECORD ON APPEAL

TO THE HONORABLE COURT OF APPEAL:

Appellant Kevin Perelman respectfully moves this Court to order supplementation and augmentation of the record on appeal in the above-referenced matter, and in support states as follows:

1. Incomplete and Deficient Appellate Record

The current reporter’s transcript provided for this appeal (B343120_CR_PERELMAN_RT.pdf) contains only the jury trial and sentencing phase (September 18 – October 1, 2024, and final sentencing). Upon review, I have determined that multiple critical pre-trial, pretrial conference, arraignment, preliminary hearing, and sentencing hearings and continuations are entirely missing from the appellate record, as documented by the trial court docket.

2. Request for Augmentation

Appellant requests the complete supplementation of all missing transcripts, including but not limited to:

• Preliminary hearings/settings: 05/22/2024, 05/17/2024, 05/03/2024, 04/05/2024, 03/15/2024, 02/26/2024, 01/12/2024, 12/11/2023, 10/17/2023
• Pretrial conferences: 07/15/2024, 09/06/2024, 06/05/2024
• Arraignment(s)/plea settings: 08/28/2023, 09/13/2023
• Additional sentencing/Nunc Pro Tunc hearings: 11/05/2024, 11/06/2024, 11/07/2024, 12/17/2024, 02/07/2025
• Any and all other hearings or proceedings missing from the record, in both Department 122 and Department E.

I respectfully request official reporter’s transcripts for the following court dates in the above-referenced criminal case:

Date	Time	Type	Result	Location	Department
02/07/2025	08:30AM	Nunc Pro Tunc Order Hearing	Not Held – Other Proceedings	Van Nuys West	Dept. – E
12/17/2024	08:30AM	Nunc Pro Tunc Order Hearing	Not Held – Other Proceedings	Van Nuys West	Dept. – E
11/14/2024	08:30AM	Probation and Sentencing Hearing	Held – Proceedings	Van Nuys West	Dept. – E
11/07/2024	08:30AM	Probation and Sentencing Hearing	Not Held – Continued by Court	Van Nuys West	Dept. – E
11/06/2024	08:30AM	Probation and Sentencing Hearing	Not Held – Continued by Court	Van Nuys West	Dept. – E
11/05/2024	08:30AM	Probation and Sentencing Hearing	Not Held – Continued by Court	Van Nuys West	Dept. – E
10/01/2024	08:30AM	Jury Trial in Progress	Held – Proceedings	Van Nuys West	Dept. – E
09/30/2024	08:30AM	Jury Trial in Progress	Held – Proceedings	Van Nuys West	Dept. – E
09/25/2024	08:30AM	Jury Trial in Progress	Held – Proceedings	Van Nuys West	Dept. – E
09/24/2024	08:30AM	Jury Trial in Progress	Held – Proceedings	Van Nuys West	Dept. – E
09/23/2024	08:30AM	Jury Trial in Progress	Held – Continued by Court	Van Nuys West	Dept. – E
09/20/2024	08:30AM	Jury Trial	Held – Continued by Court	Van Nuys West	Dept. – E
09/18/2024	08:30AM	Jury Trial	Held – Proceedings	Van Nuys West	Dept. – E
09/06/2024	08:30AM	Pretrial Conference	Held – Proceedings	Van Nuys West	Dept. – E
07/15/2024	08:30AM	Pretrial Conference	Held – Continued by Defendant	Van Nuys West	Dept. – E
06/05/2024	08:30AM	Arraignment	Held – Proceedings	Van Nuys West	Dept. – E
05/22/2024	08:30AM	Nunc Pro Tunc Order Hearing	Not Held – Other Proceedings	Van Nuys West	Dept. – 122
05/22/2024	08:30AM	Preliminary Hearing	Held – Preliminary Hearing	Van Nuys West	Dept. – 122
05/17/2024	08:30AM	Preliminary Hearing	Held – Proceedings	Van Nuys West	Dept. – 122
05/06/2024	08:30AM	Preliminary Hearing	Held – Continued by People	Van Nuys West	Dept. – 122
04/05/2024	08:30AM	Preliminary Hearing Setting	Held – Continued by Defendant	Van Nuys West	Dept. – 122
03/15/2024	08:30AM	Preliminary Hearing Setting	Held – Continued by Defendant	Van Nuys West	Dept. – 122
02/26/2024	08:30AM	Preliminary Hearing Setting	Held – Continued by Defendant	Van Nuys West	Dept. – 122
01/12/2024	08:30AM	Preliminary Hearing	Not Held – Other Proceedings	Van Nuys West	Dept. – 122
12/11/2023	08:30AM	Preliminary Hearing	Not Held – Other Proceedings	Van Nuys West	Dept. – 122
10/17/2023	08:30AM	Preliminary Setting/Resetting	Proceedings Heard	Van Nuys West	Dept. – 122
09/13/2023	08:30AM	Arraignment and Plea	Proceedings Heard	Van Nuys West	Dept. – 100
08/28/2023	08:30AM	Arraignment		Van Nuys West

• Include both morning and afternoon sessions, if applicable.
• If there are additional proceedings related to arraignment, settings, pretrial, or sentencing that are not in the appellate record, I request transcripts for those as well.

3. Specific Material Issue: May 22, 2024 Pre-Trial Hearing (Judge Marcus)

Of particular importance is the pre-trial hearing of May 22, 2024. Reviewing available audio, I noted that Judge Marcus stated:

> “My next move would be to force you out of your place.”

This statement may indicate judicial intent or bias, and is directly pertinent to claims of due process violations and lack of impartiality in the proceedings. The transcript for this hearing—and all other pretrial activity—must be included for the Court to meaningfully assess potential constitutional violations.

4. Systemic History & Ineffective Representation

This request is not made lightly. After three separate illegal cases and five attorneys—none of whom have raised meritorious claims regarding judicial and government misconduct or protected my rights with the required zeal—I am now compelled as a self-represented appellant to insist for the record that these omissions cannot be overlooked any longer. The repetition of failures by prior counsel, coupled with the filing of an opening brief without the full record or my input (while a conflict-of-interest motion was pending), makes full exposure of all misconduct a matter of record and constitutional necessity.

5. Necessity for Fair Appellate Review & Future Proceedings

A complete record is essential for this Court to review not only ordinary issues, but also to examine, as required by law, whether repeated constitutional breaches have been allowed at trial, during pre-trial, or in the selection of defense counsel. Only when every transcript—especially those evidencing potential bias or unfairness—is made part of the appellate record will meaningful review be possible, and future rights (including any habeas or federal review) preserved.

WHEREFORE, appellant requests that the Court order augmentation of the appellate record to include:

• All missing transcripts noted above (and any others omitted),
• With particular attention to the May 22, 2024 hearing and Judge Marcus’s remarks,
• And provide appellant and current/future counsel time to review and supplement any appellate arguments as needed.

Dated: 10/21/2025

Respectfully submitted,

Kevin Perelman

26500 Agoura Rd, Ste 102

Calabasas, CA 91302

312-259-3686

Declaration of Kevin Perelman in Support of Motion to Augment the Record

I, Kevin Perelman, declare as follows:

I am the appellant in this matter. The facts stated in the attached Motion to Augment the Record on Appeal are true and correct of my own personal knowledge. I make this declaration in support of my request for full augmentation of the appellate record, and I understand that this declaration is made under penalty of perjury under the laws of the State of California.

Executed on [Today’s Date] at Calabasas, California.

Kevin Perelman

Kevin Perelman

26500 Agoura Rd, Ste 102

Calabasas, CA 91302

312-259-3686

10/17/2025

The State Bar of California – Office of Chief Trial Counsel

845 South Figueroa Street

Los Angeles, CA 90017-2515

Re: Formal Complaint – Attorney Misconduct, Judicial Bias, and Systemic Due Process Violations

Case No. B343120 (Court of Appeal, Second Appellate District, Div. Four), and Related Cases 3PY034G8 and 7VW040GG

Attorneys: Shep Alan Zebberman (#155478), Yisrael Gelb (#344G24); Judges: Stephen Austin Marcus (#G7026), Gregory Arthur Dohi (#155604)

To Whom It May Concern:

I submit this formal, detailed complaint regarding egregious attorney misconduct, grossly ineffective assistance, and a persistent pattern of due process violations throughout my recent criminal trials and appeals. This complaint primarily addresses Shep Alan

Zebberman (#155478, trial counsel), Yisrael Gelb (#344924, appointed appellate counsel), and ongoing failures by the California Appellate Project – Los Angeles (CAP-LA) to ensure

impartial, qualified representation. I also flag severe concerns about judicial conduct by Judges Stephen Marcus and Gregory Dohi in Van Nuys Courthouse as integral to the failures in my cases.

Ineffective Assistance, Conflict of Interest, and Attorney Negligence:

• Shep Alan Zebberman (#155478), my trial counsel and a devout Jewish attorney, failed to investigate or present exculpatory evidence, refused to file critical motions (including full and proper Pitchess motions and a change of venue), discouraged valid defense strategies, and displayed personal animosity, including discriminatory and prejudicial attitudes. He also disclosed to me that he had personal and social ties to several judges on my case, including stating that he attended college with Judge Gregory Dohi. This raises serious concerns about conflict of interest and his failure to zealously advocate on my behalf.
• Yisrael Gelb (#344G24), my appointed appellate counsel, continues to represent me despite a clear conflict of interest. He has only two years of legal experience and is a rabbi who is closely connected to Mr. Zebberman within the Jewish community.

Mr. Gelb has not meaningfully challenged prior counsel’s failures or pursued habeas petitions or other appropriate relief. He either lacks the knowledge or is unwilling to pursue these remedies. My repeated requests to CAP-LA for reassignment on the grounds of ineffective assistance of counsel have been ignored, further evidencing the unfair and potentially corrupt handling of my trials and appeals.

Judicial Bias, Threats, and Due Process Violations:

• Judge Stephen Austin Marcus (#G7026) threatened me in open court, stating, “I’ll squeeze you out of there,” referring to my house, in a manner that was intimidating and prejudicial showing motive.
• Judge Gregory Arthur Dohi (#155604) denied essential portions of the Pitchess motion for discovery of LAPD Officer Charles Sean Dinse’s records (despite

documented federal lawsuits and evidence of misconduct), and displayed bias and conflict of interest by his close association with my trial lawyer. These failures blocked access to crucial impeachment evidence and rendered the trial unfair.

• Both judges exhibited prejudgment, intimidation, and improper relationships that contributed to a systemic lack of fairness (see attached trial notes and supporting documentation).

Pattern of Identical Due Process Violations Across Multiple Cases:

This pattern is not isolated. Nearly identical due process violations—including judicial denial of key defense motions, refusal to allow exculpatory evidence, defense counsel’s

divided loyalty, and courtroom intimidation tactics—have occurred in Case Nos. 3PY034G8 and 7VW040GG (Los Angeles County). In each, my right to a fair trial and to adequate,

independent counsel was systematically undermined by the same types of misconduct and institutional bias. Details of these proceedings, docket records, and court filings are attached for your review.

Systemic CAP-LA and Administrative Failures:

Despite repeated, written requests, I have never received official notice or communication by mail regarding attorney appointments, relevant deadlines, or changes in my appellate counsel. Court docket inconsistencies—including future-dated proofs of service and a

“replace appointed counsel” order never acted on—compound my due process concerns. Communications with CAP-LA leadership (see attached email) show a disregard for my

conflict and experience concerns and an unwillingness to ensure compliance with legal and ethical standards.

Concerns about Attorney Assignment and Transparency:

I would also like to bring to your attention serious irregularities in the assignment of my appellate counsel, Yisrael Gelb (#344924). According to the official CAP-LA Attorney/Staff Directory (October 2025 printout, attached), Mr. Gelb does not appear as a staff or

recognized panel attorney with CAP-LA. This lack of transparency is deeply concerning, especially as I have reason to believe he may have been brought into my case through personal, family, or community connections, rather than through CAP-LA’s formal

assignment process. The combination of his absence from the public roster and his close community ties to my previous counsel, Shep Alan Zebberman, has heightened my

concerns regarding conflict of interest and the lack of independent, impartial appellate

representation. I respectfully request that the State Bar and appropriate oversight agencies investigate whether proper procedures were followed in Mr. Gelb’s appointment and

whether any inappropriate influence or favoritism played a role.

Request for Investigation and Disciplinary Action:

I respectfully request:

• A full investigation into the conduct of Shep Alan Zebberman (#155478), Yisrael Gelb (#344924), and the active roles of Judges Marcus and Dohi in these proceedings.
• Supervisory inquiry into CAP-LA’s attorney assignment process and its response to my complaints.
• Remedial, disciplinary, or corrective actions as warranted, including notice to the relevant judicial oversight body.

All claims are supported by the attached exhibits, IAC statements, trial notes, habeas filings, and record excerpts.

Attachments Index:

1. Second letter to CAP after ignoring first request
2. CAP-LA Attorney/Staff Directory, October 2025 printout
3. Email from Rick Lennon (CAP-LA), September 14, 2025
4. Appellate court docket screenshots (“replace appointed counsel”)
5. Proof of Service Date 10/20/2025 instead of 10/15/2025 inconsistencies
6. Criminal cases (now including 3PY03498 and 7VW04099)
7. Prior request for reassignment of appellate counsel (August 4, 2025)
8. Statement of Ineffective Assistance of Counsel and Petition for Writ of Habeas Corpus
9. Ineffective Assistance, Misconduct C Corruption Statement – Trial Judicial Misconduct – Notes

Thank you for your attention and immediate review. Please confirm receipt and advise if further documentation or testimony is required.

Sincerely,

Kevin Perelman

Attachment 1

Second letter to CAP after ignoring first request

Kevin Perelman

26500 Agoura Rd, Ste 102

Calabasas, CA 91302

312-259-3686

10/16/2025

California Appellate Project – Los Angeles

Attn: Executive Director Jennifer Peabody (or Supervising Attorney) 520 S. Grand Ave, 4th Floor

Los Angeles, CA 90071 Phone: (213) 243-0300

Fax: (213) 243-0303

Email: Capdocs@lacap.com

Re: Request for Appointment of New Appellate Counsel and Formal Complaint – Case No. B343120

To Whom It May Concern:

I urgently reiterate my request for the appointment of new appellate counsel and submit this formal complaint regarding the ongoing mishandling and oversight of my appeal, Case No. B343120.

Conflict of Interest, Prejudice, and Attorney Selection Concerns

My trial attorney, Shep Alan Zebberman (#155478), was privately retained and provided

ineffective assistance of counsel. My current appellate counsel, Yisrael Gelb (#344924), is a rabbi and presents a clear religious identity. I am Jewish myself, but I have observed a troubling pattern in which nearly all attorneys assigned to me—either by the courts or CAP—share the same tight-knit community affiliation, sometimes with visible religious leadership roles. This pattern raises concerns that attorney selection, rather than being

impartial and neutral, may be influenced by factors risking divided loyalty and bias. I firmly believe that religion and law should remain strictly separate in professional legal

assignment. I request oversight and transparency to ensure fairness and diversity in attorney assignment.

Inexperience of Appointed Counsel

Yisrael Gelb, according to state bar records, has only been licensed for approximately two years. This minimal experience is deeply concerning, as my appeal involves complex

constitutional issues, alleged judicial and prosecutorial misconduct, and a significant

impact on my future. It is simply not appropriate for a case with these stakes to be assigned to an attorney this inexperienced.

Omission from CAP-LA Directory

Upon reviewing the official CAP-LA staff/panel listing (see Attachment 1), I found that Mr. Gelb does not appear as a staff or recognized panel attorney. I respectfully request an explanation of how he was assigned and whether standard CAP-LA procedures have been followed.

Lack of Notice or Communication

For the record, I have never received any official notice, written correspondence, or other communication by mail regarding the appointment or substitution of appellate counsel, relevant deadlines, or any related matters in this case from CAP-LA or the court.

All information I have obtained has come from my own online docket research or direct

inquiry. This highlights a serious breakdown in due process and communication affecting my rights.

CAP-LA Communication (Rick Lennon Email) and Inferred Denial of New Counsel Attachment 2 is an email from Rick Lennon of CAP-LA, dated September 14, 2025. While Mr. Lennon does not expressly deny my request for new counsel, he makes it clear that CAP-LA intends to keep Mr. Gelb on my case despite my repeated, written objections. The substance of the email disregards my concerns about conflict of interest, the importance of habeas expertise, and procedural fairness.

Case Docket Irregularities

Attachment 3 contains screenshots of the state court docket showing a “replace appointed counsel” notice dated 10/15/2025. I was never contacted by a new attorney, no

substitution took place, and there are proofs of service filed with dates set in the future (see Attachment 4). This raises further concerns about transparency, accuracy, and

reliability in my case record.

Systemic Pattern and History in Prior Cases

This is not the first time I have experienced such issues in Los Angeles County. I have had two prior criminal cases—Case No. 3PY03498 and Case No. 7VW04099—where similar problems occurred. Lawyers with community or religious ties, or a disposition toward prejudice or coordinated adverse action, resulted in unfair or ineffective representation. I respectfully submit that these repeated problems indicate a broader, systemic issue with how representation is being assigned and overseen in my matters. (See Attachment 5 for detailed summary.)

Comprehensive Record of Documented Complaints and Habeas Petition

In addition, please see:

• Attachment 6: My initial written request for new counsel (August 4, 2025), which has not been addressed, and a record that an opening statement was filed on 10/13/2025 instead.
• Attachment 7: Statement of Ineffective Assistance of Counsel and Petition for Writ of Habeas Corpus, summarizing my legal arguments and supporting evidence.
• Attachment 8: Ineffective Assistance, Misconduct C Corruption Statement – Trial Judicial Misconduct – Notes, providing additional detail on courtroom and systemic misconduct.

Request for Immediate Action

For all these reasons, I respectfully and urgently request:

• Immediate appointment of new appellate counsel, independent from prior

attorneys, fully vetted, and with no close community or religious ties to previous defenders.

• Written clarification of CAP-LA’s process for assigning Mr. Gelb to my case, why his name does not appear on your staff/panel directory, and what supervisor-level

review (if any) has been conducted.

• Assurance that no actions are taken in my appellate matter until impartial, conflict- free, and sufficiently experienced counsel has been assigned, and a supervisor has confirmed full review and corrective action in my file.

Thank you for your immediate attention. Please ensure this letter and all supporting attachments are made part of my official appellate file. I respectfully request a formal, written response as soon as practicable.

Attachments:

1. CAP-LA Attorney/Staff Directory, October 2025 printout
2. Email from Rick Lennon (CAP-LA), September 14, 2025
3. Appellate court docket screenshots (“replace appointed counsel”)
4. Proof of Service Date 10/20/2025 instead of 10/15/2025 inconsistencies
5. Criminal cases (now including 3PY03498 and 7VW04099)
6. Prior request for reassignment of appellate counsel (August 4, 2025)
7. Statement of Ineffective Assistance of Counsel and Petition for Writ of Habeas Corpus
8. Ineffective Assistance, Misconduct C Corruption Statement – Trial Judicial Misconduct – Notes

Sincerely,

Kevin Perelman

Attachment 2

CAP-LA Attorney/Staff Directory, October 2025 printout

Attachment 3

Email from Rick Lennon (CAP-LA), September 14, 2025

Attachment 4

Appellate court docket screenshots (“replace appointed counsel”)

Attachment 5

Proof of Service Date 10/20/2025 instead of 10/15/2025 inconsistencies

Attachment 6

criminal cases (now including 3PY03498 and 7VW04099)

Van Nuys Courthouse Cases with Judicial Misconduct: criminal cases:

3PY03498

7VW04099

Attachment 7

Prior request for reassignment of appellate counsel (August 4, 2025)

To

California Appellate Project

Phone: Phone: (213) 243-0300

Fax: (213) 243-0303

August 4, 2025

Email:Capdocs@lacap.com AppellateBranch@pubdef.lacounty.gov

Adress: 520 South Grand Avenue, 4th Floor Los Angeles, CA 90071

To Whom It May Concern:

The People v. Kevin Perelman, Case No. B343120 Court of Appeal, Second Appellate District, Division Four

Dear Supervising Attorney,

I am writing to formally request the reassignment of new appellate counsel in my case, The People v. Kevin Perelman, Case No. B343120, currently before the Court of Appeal, Second Appellate District, Division Four.

I have serious concerns about a potential conflict of interest that could affect my representation. While my current appointed appellate attorney has not acknowledged any conflict, I feel there is a strong likelihood of one due to community affiliations and the circumstances of my case. Both my previous trial attorney and the current appellate attorney are members of the same small, close- knit community (the Jewish community), and my current appellate attorney is also a Rabbi. I am concerned these community connections may create both the appearance and reality of divided loyalty, and possibly an unwillingness to fully pursue claims involving another member of the same community.

Additionally, I am concerned about my appointed appellate attorney’s limited experience (approximately two years since passing the bar), which I believe is insufficient for a case of this seriousness and complexity. As an inexperienced lawyer, he may not possess the necessary knowledge or familiarity with habeas corpus proceedings. He has told me directly that he believes he is limited to what is included in the trial transcripts and docket, even though filing a writ of habeas corpus is often necessary to address ineffective assistance of counsel based on facts outside the transcript and docket.

It is especially important to note that my case may also involve significant judicial and prosecutorial misconduct. My concerns include, but are not limited to, fraudulent police reports, improper investigative practices, potential bias or unfair treatment from both the prosecution and the trial court, and witnesses conspiring with police in illegal operations. I am deeply concerned that these issues have substantially impacted the integrity and fairness of my trial, and that they warrant careful and impartial review on appeal. I believe my current appellate counsel is not adequately positioned, either in terms of experience or independence, to thoroughly investigate and argue these matters, especially where those issues involve or are intertwined with claims of ineffective assistance of counsel.

For these reasons, I respectfully request that a new appellate attorney —one with no prior professional or personal association with my previous legal counsel, not a member of the same religious or social network, and who is highly experienced with both direct appeals and habeas corpus claims—be assigned to handle my appeal. It is critically important to me that my appellate representation is impartial and fully qualified to pursue all necessary legal remedies, including direct challenges to judicial or prosecutorial misconduct and the involvement of witnesses in illegal conduct.

I trust that you will carefully review my concerns and take timely action to ensure fair representation as required by law. Thank you for your attention to this urgent and sensitive matter.

Sincerely, Kevin Perelman

Kevin Perelman

Appellant

26500 Agoura Rd, STE 102

Calabasas, Ca 91302

312-259-3686

Kevin@KevinPerelman.com

Attachment 8

Statement of Ineffective Assistance of Counsel and Petition for Writ of Habeas Corpus

To

California Appellate Project

Phone: Phone: (213) 243-0300

Fax: (213) 243-0303

Email:Capdocs@lacap.com AppellateBranch@pubdef.lacounty.gov Adress: 520 South Grand Avenue, 4th Floor Los Angeles, CA 90071

To Whom It May Concern:

The People v. Kevin Perelman, Case No. B343120 Court of Appeal, Second Appellate District, Division Four

Petition for Writ of Habeas Corpus

Ground: Ineffective Assistance of Counsel — Presentation of New and Extrinsic Evidence

1. Petitioner’s Claim: Ineffective Assistance of Counsel

Petitioner, Kevin Perelman, respectfully seeks habeas corpus relief based on egregious ineffective assistance of counsel by Shep Zebberman, as demonstrated by facts both in and outside the trial record. This claim is supported by the following:

1. Legal Standard (Strickland v. Washington) Relief is warranted when:
   1. Counsel’s performance was constitutionally deficient;
   2. There is a reasonable probability that, but for counsel’s unprofessional errors, the result would have been different.
2. Statement of Facts C New Extrinsic Evidence

Discriminatory and Prejudicial Conduct

• • • Shep Zebberman made prejudiced statements and failed to advocate for me due to personal and community bias, as described in my declaration and corroborated by third-party witnesses and community records.

Failure to Investigate, Prepare and Present Defense

• • • Did not review or present extensive video evidence of mobbing, vandalism, and ongoing harassment in conspiring methods and events with LAPD.
    • Refused to meet with me to discuss my side of events, relying solely on prosecution evidence.

Failure to Investigate or Call Available Witnesses

• • • Never investigated, interviewed, or subpoenaed witnesses who could have testified on my behalf, including:
• Eyewitnesses to harassment, vandalism, and provocation;
• Neighbors and community members familiar with false allegations by Officer Dinse, Terrance Scroggins, Pedram Espinoza, and others;
• Victims of Officer Dinse’s similar misconduct (e.g., federal lawsuit by Rex Schillenberger);
• Experts in police procedure and community mobbing.

Failure to hire or consult with any private investigator who could have

interviewed witnesses, gathered additional exculpatory statements, or tracked social media campaigns against me.

• • Evidence: Declarations from available witnesses, statements from those never

contacted by defense, my own sworn declaration, investigator reports (if available), and a list of potential witnesses with what their testimony would have shown.

• • Failure to introduce events of police harassments, intimidation, as well as witness harassment, intimidation, before and during the trial.

Failure to File Key Motions and Argue Self-Defense

• • • Did not file a Pitchess motion against Officer Dinse, despite his documented history of similar misconduct.
    • Refused to argue self-defense even with documentary/video evidence of years-long provocation by community and police.
    • Did not challenge fabricated restitution claims or expose documented blackmail efforts by prosecution witnesses. Working with their friends in the court house to pose as FBI agents for intimidation.

Conflict of Interest s Coercion Toward Insanity Plea

• • • Prioritized relationships with trial judges over client defense.
    • Pressured me to accept Not Guilty by Reason of Insanity (NGI) without legal/medical basis.

Failure to Seek Change of Venue or Protect Against Community Harassment

• • • Ignored repeated, documented attempts by Officer Dinse and neighborhood watch to incite community bias, including via Facebook and public statements.
    • Did not move to change venue despite mass prejudice, nor did he advise or assist with seeking restraining orders against harassers.

Failure to Impeach Prosecution Witnesses

• • • Did not challenge (impeach) perjured or contradictory testimony from key

witnesses, and did not present readily available impeachment material (videos, letters, reports).

Failure to Protect Defendant from Direct Courtroom Intimidation

• • • Did not object or seek mistrial when individuals impersonating FBI agents appeared in the courtroom with Prosecutor Orbelli to intimidate me in the

presence of the judge and jury—egregious misconduct designed to prejudice my defense, create an unfair environment, and reinforce false government narratives.

• • • Failed to raise the issue of prosecutorial collusion with these individuals and did not seek judicial intervention or police report to expose this unlawful intimidation tactic.
    • Evidence: My declaration, affidavits from anyone who witnessed or heard about the “FBI” presence, court security reports, and any correspondence with court staff about these incidents.

G. Additional Examples of Evidence Outside the Trial Record

• Newly available police records or Bar complaints showing patterns of misconduct not included in trial evidence.
• Social media posts by Officer Dinse or others, including deleted/archived content recovered through subpoenas.
• Expert opinions now available but not sought by defense (e.g., on police procedure, mobbing, prejudice).

1. Prejudice: Strickland Standard Satisfied Because of the above errors:

• The jury never heard or saw critical exculpatory evidence or witness testimony that would have undermined the prosecution’s case.
• Lack of a private investigator, lack of witness interviews, and failure to object to intimidation fundamentally denied me a fair trial.
• The outcome would likely have been different had defense counsel met even minimal professional standards.

1. Prayer for Relief and Request for Evidentiary Hearing

Petitioner respectfully requests:

• 1. An order to show cause and/or evidentiary hearing to receive this new, extrinsic evidence.
  2. Vacation of conviction and/or outright dismissal due to cumulative constitutional error.

1. Evidence to be Attached (Example)

• Declaration of Kevin Perelman (listing all witnesses I requested or identified, complaints re: FBI impersonators, failure to investigate)
• Declarations/affidavits from uninvestigated witnesses, neighbors, and potential experts
• Affidavit from (or record of attempted contact with) a private investigator, if available
• Videos and audio not introduced at trial
• Screenshots/archived copies of relevant Facebook/social posts
• Security/court incident reports regarding presence of FBI agents or intimidation efforts
• Insurance, restitution, and any financial records relating to blackmail/extortion claims
• Copies of relevant Bar complaints, police records, or civil complaints

Attachment 9

Trial Judicial Misconduct – Notes

To

California Appellate Project

Phone: Phone: (213) 243-0300

Fax: (213) 243-0303

Email:Capdocs@lacap.com AppellateBranch@pubdef.lacounty.gov Adress: 520 South Grand Avenue, 4th Floor Los Angeles, CA 90071

To Whom It May Concern:

The People v. Kevin Perelman, Case No. B343120 Court of Appeal, Second Appellate District, Division Four

Ineffective Assistance of Counsel and courtroom misconduct – Shep Zebberman Specific Accusations:

• Discriminatory and Prejudicial Comments
• Sheps Statement to me, right before the verdict “You might get away with this” Showing from day one, he was acting as a judge, not a Lawyer. And was never going to represent me fairly and was involved in a conspiracy to lock me away no matter how innocent. No matter how much proof. He wasn’t even going to try to prove my innocence.
• Everything asked he give an opposite answer, and disinformation, showing anger. I asked about change of venue. like change of venue, he lied stating their was not

grounds for. While was friends with a lot of the Judges. Being provoked and harassed by witness Terrance Scroggins during trial. Would not help with filing restraining

orders or use the information to show in the court at any time that Terrance was always the aggressor or impeach the witnesses properly jumping from lawyer to lawyer.

– Penal Code § 147: Willful deprivation of a client’s rights

Failure to Investigate/Prepare/Defend

• Did not review Kevin’s exculpatory video evidence or ask for Kevin’s version of events. – Relied on fabricated reports and prosecution narrative. – Penal Code § 1054.G: Failure to seek or present exculpatory evidence

Failure to File Key Motions

• Judge Dohi, refused to file Pitchess motion for LAPD Officer Charles Sean Dinse, despite Dinse’s federal lawsuits for similar behavior. – Would not request change of venue or move for mistrial, nor file dismissal. Even with the events happening in the court room – Penal

Code § 1054.5: Withholding of motions/evidence

Conflict of Interest

• Admitted being friends with Judge Gregory A. Dohi and Judge Stephen Marcus, failed to zealously advocate for client. – Potentially took $50,000 under false pretenses (with

influence from Arnold Silber, Kevin’s stepfather). – Penal Code § 182(a)(5): Conspiracy to obstruct justice

Coercion Toward Insanity Plea (NGI)

• Tried to pressure client to plead NGI to “get you out of this,” abusing attorney’s

power/trust. Stating “I can get you out of this” I know some Psychology People – Business s Professions Code § 6068: Duty to act with honesty and loyalty

Refusal to Provide Self-Defense Argument

• Refused to present documented mobbing/stalking history; said self-defense not possible for vandalism despite clear evidence of gangstalking and conspiracy amongst mass

stalking groups with LAPD with an Agenda to setup or frame the defendant. – Penal Code § 6G2-6G4: Legitimacy of self-defense argument

Judicial Corruption s Misconduct Specific Accusations:

• • Bias and Prejudice
• Judge Stephen Marcus: “I’ll squeeze you out of your place.”
• Judge Gregory A. Dohi: Fabricated mental health diagnoses, belittled and intimidated

defendant (“Come on down!”) treating court rooms and trials like fun game shows, denied defense motions for Pitchess; colluded in systemic prejudice.

• Penal Code § G6 s G6.5: Judicial officers acting corruptly, maliciously, or with conflict of interest

Van Nuys Court Reporter who owns property adjoining my wall Misconduct – Debbie Wollman

• Spread false rumors about Kevin’s mental health to court staff and judges; owned

property adjoining defendant (conflict of interest). – Omitted critical exculpatory phrases from transcripts (e.g., “Every Miata is modified”). – Penal Code § 134: Preparing false

evidence (tampered transcript) – Penal Code § 182: Conspiracy

Police Corruption – Officer Charles Sean Dinse Specific Accusations:

• • History of Lawsuits and Misconduct
• Used Facebook to incite neighborhood harassment against Kevin; earlier federally sued by Rex Schillenberger.
• Publicly posted “How do we FORCE people into mental facilities,” inciting community intimidation/hate/Stalking groups.
• Penal Code § 182: Conspiracy to violate civil rights
• Penal Code § 135: Destroying/concealing evidence

Fabrication of Claims and Evidence

• Lied about Kevin following him with Prosecutor Orbell to use as amo for increased

sentencing, staged incidents to provoke legal trouble. – Seized art computer (falsely called a “hard drive”), made misleading claims about data. – Penal Code § 118: Perjury – Penal Code § 141: Planting/tampering with evidence

Intimidation and Collusion

• Orchestrated use of “fake FBI agents” to intimidate Kevin in courtroom right before trial day. – Colluded with Prosecutors Lisa Orbelli and Detective Ruiz, and Charles Sean Dinse.
• Penal Code § 136.1: Witness/victim intimidation – Penal Code § 182: Conspiracy

Witness and Community Misconduct

Specific Accusations:

• • Terrance Scroggins (Neighbor/Witness):
• Engaged in continuous harassment/provocation before and during the trial(240+ videos), staged vandalisms with neighbors, Provokings, submitted false restitution claims (colluded with USAA Insurance to repaint entire car, then sought extra $5,000 after USAA paid for

repairs).

• Left blackmail threats in writing demanding DIRECT restitution money.
• Penal Code § 518: Extortion
• Penal Code § 118: Perjury

Pedram Espinoza (Neighbor/Witness):

• Provided knowingly false testimony about his time at the property and his encounters with Kevin. – Penal Code § 118: Perjury. No impeaching the witness with Pedram on video stating I’m not allowed at my townhouse complex. Or that I take pictures of kids. Showing he’s defaming my name and has motive to get rid of me. Shep kept the argument in the

context to make it look like I was loitering around his house, in the common areas of our complex. A Juror had to ask the Judge how long I lived their he picked up one the one sided stories.

Community Members (“Yosi,” Jason Ryan Fishman, etc.):

• Participated in organized surveillance/harassment; repeated slander (“not a real Jew,” “mentally ill”), acted at direction of Officer Dinse and neighborhood watch. – Penal Code §

653.2: Electronic/cyber harassment – Penal Code § 182: Conspiracy to harass. Showing linked events within the Jewish Community.

Prosecutorial Misconduct Specific Accusations:

• Lisa Orbelli s Detective Ruiz (Prosecutors):
• Collaborated with police and witnesses to create “incidents” for prosecution; made false claims and permitted intimidation tactics in and around the courthouse.
• Permitted/introduced false evidence, allowed staged intimidation (fake FBI agents and courthouse staff).
• Penal Code § 118: Subornation of perjury
• Penal Code § 182: Conspiracy
• Penal Code § G6.5: Misconduct by officers of the court

Transcript, Records, and Restitution Tampering Specific Accusations:

• • Omitted or altered evidence/testimony in trial transcripts (Debbie Wollman).
  • Docket/minute orders contained unexplained errors or clerical manipulation (split sentence, “no probation” issues), possibly at the direction of corrupt clerks and neighbor/court reporter Debbie Wollman.
  • Restitution awarded based on fraudulent insurance claims and blackmail tactics (Terrance Scroggins).
  • Penal Code § 134: Preparing false documentary evidence
  • Penal Code § 115: Filing false instruments

Overarching Constitutional and Civil Rights Violations Specific Accusations:

• • Constitutional:
• Denial of due process (U.S. Const. Amend. XIV)
• Denial of effective assistance/counsel (U.S. Const. Amend. VI; Strickland v. Washington)
• Denial of fair trial and equal protection (California Const. Art. I, §§ 7, 15)

Pattern of Systemic Government Abuse:

• Collusion among judges, defense, prosecutors, police, and community.
• Tampering, intimidation, and long-term targeting that makes fair retrial impossible.
• Penal Code § 182: Criminal conspiracy
• Civil Remedies: 42 U.S.C. § 1983 (federal civil rights suit for deprivation of rights under color of law)

Judicial Corruption—Grounds for Dismissal Overlooked

• • Repeated Judicial Bias:
• Judge Stephen Marcus made overtly hostile comments toward Defendant (“I’ll squeeze you out of your place”), demonstrating clear personal animosity and prejudice contrary to impartial adjudication required by law.
• Judge Gregory Dohi fabricated “mental illness” labels for Defendant with no clinical basis, belittled Defendant during proceedings, and denied valid defense motions (e.g., Pitchess motion for Officer Dinse), demonstrating pattern of prejudiced rulings.

Legal Basis: Judicial bias and partial are grounds for mistrial or dismissal:

• *Caperton v. A.T. Massey Coal Co.*, 556 U.S. 868 (2009) (extreme judicial bias may violate due process).
• Cal. Penal Code § 96, § 96.5 (corrupt conduct by judicial officers).

Court Reporter Misconduct s Transcript Tampering:

• Debbie Wollman, with a direct conflict of interest, fabricated negative mental health rumors about Defendant to judges and staff, and altered the official record (omitting

exculpatory testimony such as “Every Miata is modified”). Legal Basis: Cal. Penal Code § 134 (preparing false evidence), § 182 (conspiracy to pervert justice).

Police Officer Corruption—Grounds for Dismissal Overlooked

• • Officer Charles Sean Dinse’s Documented Corruption:
• Used his Facebook account to incite community mobbing (“How do we FORCE people into mental facilities”), was previously federally sued for similar actions.
• Lied under oath about Defendant following him with Prosecutor Orbelli for increased

sentencing, fabricated incidents, and seized Defendant’s computer misrepresenting both its contents and evidentiary value.

• Regularly engaged in provocation and intimidation designed to escalate Defendant’s legal peril.

Legal Basis:

• Cal. Penal Code § 118 (perjury), § 141 (evidence tampering), § 182 (conspiracy), § 147 (officials depriving rights).
• Cal. Evidence Code § 1043 et seq. (Pitchess motion—officer history of dishonesty/abuse is grounds for discovery, impeachment, and, where egregious, dismissal).

Prosecutorial Misconduct—Compelling Grounds for Dismissal Ignored

• • Fabrication, Coll, and Use of False Evidence:
• Prosecutors Lisa Orbelli and Detective Ruiz collaborated with Dinse, Scroggins and others, knowingly presenting false or uninvestigated claims to the court.
• Prosecutors enabled and facilitated courtroom intimidation—including the appearance of people posing as FBI agents during trial—creating an atmosphere of threat and

unlawfulness.

• Prosecutors injected irrelevant hearsay and prejudicial evidence into the record, repeatedly straying from the charges to paint Defendant as dangerous or unstable, manipulating judicial perception and deliberation.

Legal Basis:

• *People v. Batts* (2003) 30 Cal.4th 660, 693 (dismissal appropriate in egregious government misconduct).
• Cal. Penal Code § 118 (subornation of perjury), § 182 (conspiracy), § 96.5 (prosecutorial misconduct).

Admission of Hearsay/Irrelevant Allegations:

• Prosecutors repeatedly introduced and relied on one sided prejudicial statements and hearsay incidents—statements, rumors, alleged threats, and unrelated community disputes—irrelevant to the charged offenses, used solely to inflame and manipulate the judge and jury. – Defense counsel failed to object or move to strike these prejudicial and

improper references, compounding the miscarriage of justice. Legal Basis: – Cal. Evidence Code § 1200 (hearsay inadmissibility), – *People v. Fuiava* (2012) 53 Cal.4th 622

(admission of repeated, irrelevant misconduct evidence is reversible error).

Cumulative Misconduct Clearly Justified Dismissal

• • Pattern of Collusion:
• Combined judicial, police, and prosecutorial bias, evidenced by intimidation, tampering, and fabrication, destroyed any pretense of fair trial.
• Egregious conduct rises to the constitutional standard where “the only appropriate remedy is dismissal,” as retrial would merely replicate injustice.

Missed Opportunities for Relief:

• At each stage—pretrial (based on evidence fabrication/transcript tampering), during trial (judicial bias, police perjury, prosecutorial hearsay, intimidation), and post-trial (restoration of rights, clerical errors)—counsel declined to move for dismissal.

Grounds for Dismissal (Relief Requested):

• • Cumulative due process violations.
  • Systemic government misconduct and collusion.
  • Prejudice so severe retrial would be unjust and constitutionally insufficient.
  • Legal authorities: US and California Constitution, People v. Batts (2003), Strickland. Washington (4), Caperton v. Massey (2009), Penal Code §§ 96, 96.5, 147, 182.

To:

Judicial Council of California

455 Golden Gate Avenue

San Francisco, CA 94102

From:

Kevin Perlman

26500 Agoura Rd, Suite 102

Calabasas, CA 91302

Phone: (312) 259-3686

Date: 10/20/2025

Subject:

Formal Complaint and Request for Oversight — Judicial Misconduct, Police Collusion, and Denial of Constitutional Rights

Judicial Council of California

Kevin Perlman

26500 Agoura Rd, Suite 102

Calabasas, CA 91302

Phone: 312-259-3686

Date: 10/20/2025

To:

Judicial Council of California

455 Golden Gate Avenue

San Francisco, CA 94102

Subject: Formal Complaint and Request for Oversight — Judicial Misconduct, Police Collusion, and Denial of Constitutional Rights

Related Case and Appeal Numbers:

• Appeal: B343120
• Superior Court Case: LA099813
• Associated Cases: 3PY03498, 7VW04099

Dear Members of the Judicial Council of California,

For more than two decades, I have been met with consistent and unwarranted hostility from individuals within law enforcement, the courts, and community-policing networks. Across extremely large social and professional circles, this conduct has not been isolated or coincidental—it has followed a continuous pattern of intimidation, reversed reporting, and retaliation. Despite my repeated efforts to seek help through proper legal and administrative channels, my attempts to report crimes or defend myself have been met not with protection, but with further hostility and prosecution. I can trace this pattern back to early childhood, even as those involved attempt to justify their actions under the guise of “mental illness” narratives.

By 2008, this hostility had become overtly threatening. While peacefully walking at a public park and filming a fire truck roughly one hundred yards away out of curiosity, LAPD officers on scene threatened my life, stating on video, “We’re watching you, Perelman.” This incident demonstrated that the targeting extended directly from law enforcement personnel themselves, well before the later prosecutions and community-based harassment escalated.

This pattern continues wherever I go, as I am routinely met with unwarranted daily anger and hostility. I have been subjected to further unlawful proceedings in which I was again denied proper legal representation and a fair hearing. Despite repeated requests for conflict-free counsel, I was assigned attorneys who ignored exculpatory evidence and refused to raise clear procedural and constitutional violations. These same issues persist in my ongoing appeals, where my filings have been disregarded and my ability to present a full and accurate record continues to be obstructed.

I respectfully request that the Judicial Council exercise its oversight authority to review these matters in light of repeated violations of due process, denial of effective counsel, and patterns of bias and misconduct by judicial officers and law enforcement personnel. Over the past several years, I have been subjected to three unlawful trials and multiple appeal obstructions, compounded by judicial and police conduct that has fundamentally undermined public trust in the impartiality of the courts.

For more than two decades—since 2001, finding out what was going on—I have faced escalating harassment and intimidation that began with death threats from my former business partner, Michael Patrick Huntley, who befriended me when I was fourteen. Since then, I have endured a sustained pattern of stalking, provocation, defamation, and fabricated accusations. The overall pattern has repeatedly conveyed the message—directly and indirectly—that “We are using the Judicial System Against you” rather than to protect me. The incidents described here represent only a few examples of what I have endured since discovering the pattern in 2001.

Despite hundreds of police reports and extensive video documentation, law-enforcement agencies have consistently refused to investigate or protect me from these angry mobs. Internal Affairs has repeatedly received detailed complaints with evidence over the years, yet either declined to act or issued watered-down findings. Of particular concern are Officer Toro, who made statements interpreted as threats toward me and my studio photography work, stating, “If you ever take a picture of a person, I will exercise the law in my own way,” and Lead Officer Charles Sean Dinse of the LAPD Topanga Division, whose conduct was the subject of prior federal civil litigation in Rex Schillenberger v. City of Los Angeles involving similar allegations of misconduct and mobilizing or encouraging community harassment groups against other individuals, including myself.

When I filed a Pitchess motion seeking disclosure of Officer Dinse’s disciplinary and complaint history to demonstrate relevance and pattern, Judge Gregory A. Dohi refused to grant the motion regarding Charles Sean Dinse, preventing access to records that could have established credibility issues and prior misconduct. Public records also show that Chief Michael Moore and Officer Dinse have been named in related actions. I ask that your Office review those records to determine whether any conflict, pattern of behavior, or departmental protection relevant to my situation exists.

One of the many more aggressive events was a month after a prior confrontation in which a man in the surrounding complex, handling a large dog, threatened my life, stating words to the effect of, “You’d better accept what’s going on or it’s going to get a lot worse for you.” They had a problem with me taking walks, getting fresh air, and exercise. On the later occasion, I walked outside my residence and discovered my vehicle had been vandalized, just once out of hundreds of times: the words “Penal Code 187” were written on the car, objects were glued to its surface, and a single glove was left on it while nearby individuals made remarks referencing the O.J. Simpson case. I immediately called the police to report the vandalism and threatening language directed at me and waited outside for officers to arrive. While waiting, the same man emerged with his girlfriend and the same dog, initiated a loaded conversation, and as I was walking away, it appeared the dog was trained to attack on cue, and the girl started punching me from behind and trying to steal the camera that I was using to document the car damage. This caused severe injuries to my leg.

The animal’s behavior suggested formal training, possibly police-level training, although I cannot verify that within this correspondence. These incidents were documented with photographs and video, yet no substantive investigation or protective action followed. The entire incident is on video, like so many others, and was provided to Detective Angela Stewart and Detective Shapiro of the LAPD Topanga Division in Los Angeles, along with hospital reports and photographs documenting my leg injuries. Despite this clear evidence, Detective Shapiro stated that I suffer from mental illness and that the incident had not occurred. Prosecutor Karine T. Phillips later claimed in court that “Kevin is trying to force cards on people,” when in reality, as shown on video, the dialogue was simply: “Would you like a card?” — “Oh, never mind, you already have one.”

In several instances across different reports, I have observed that when I called police to report crimes committed against me, the reporting process appeared to be reversed—resulting in criminal allegations filed against me rather than against those responsible for the underlying acts. Several of the individuals involved appeared connected with neighborhood or “community-policing” activities and acted as though they were empowered by law enforcement to intervene or intimidate. I respectfully request that these events, and the handling of the related police reports and subsequent charges, be reviewed in detail to determine why no proper investigation occurred and whether any link exists between these individuals and community-policing programs operating under the Los Angeles Police Department.

Another serious example occurred around 2017, when Bailey Bernard followed me home from Warner Center Park, a public park where I have repeatedly faced unwarranted hostility and daily provocations from individuals with no legitimate reason to interfere with me—other than participation in organized hate-based mobs expressing animosity through statements such as “Your kind” and we don’t want you here or anywhere else. During that period, I was also subjected to explicit racial threats, including “No relaxing for you, n****r,” and other intimidating remarks clearly intended to provoke confrontation. As I entered the gate to my townhouse complex, Bernard asked, “Is this where you live?” and struck the keys from my hand, physically assaulting me. I immediately called 9-1-1 and later went to the police station to file a report. Instead of investigating the assault, LAPD filed assault charges against me.

During the subsequent trial, Prosecutor Karine T. Phillips falsely stated that I had never called 9-1-1, and Defense Attorney Seymour Amster—who could have easily obtained the 9-1-1 call records proving otherwise—refused to do so. His refusal mirrored his handling of other exculpatory evidence, including the 2017 parking citation personally issued to me by witness and arresting officer Lead Officer Charles Sean Dinse of the LAPD Topanga Division, just two weeks before I took the stand in that same trial. Toward the end of those proceedings, Defense Attorney Amster remarked, “You’re brilliant; this is about mental illness,” referencing mental-illness watch lists in a way that appeared intended to frame the situation rather than address the facts. Putting mental illness labeling above law and order, and keeping people safe.

There has never been any legitimate mental-health basis for such statements, other than unverified claims from an angry family attempting to manipulate outcomes. Rather, this language has been used to portray me as mentally ill in order to discredit my testimony and minimize documented misconduct. This tactic, coupled with reversed police reports and suppression of evidence, has contributed to a continuing pattern of institutional retaliation and defamation that persists to this day.

Another area of serious concern involves Court Reporter Debbie Wollman of the Van Nuys Courthouse, who for approximately twenty years owned the townhouse directly adjoining mine—sharing a common wall—but never resided there. This property ownership presents a clear conflict of interest, as Ms. Wollman works at the same courthouse where many of my hearings and trials have taken place. The property has appeared online in connection with “Going Vertical, Inc.”, a corporate name previously proposed by Mike Huntley, which raises additional questions about potential judicial or professional impropriety linked to that location. Notably, Ms. Wollman sold the adjoining property shortly after I was released from custody, a timing that further raises questions regarding possible undisclosed relationships or conflicts connected to that residence and her position at the courthouse.

Ms. Wollman appears in at least three videos: one from 2017, in which she tells me that I am “not allowed at the courthouse,” during my trial, and two later encounters in 2025, shortly after I was released from custody and again within the following month, where she approached me unsolicited—saying “no hard feelings” as if we were in some form of personal competition—and insisting that I “admit” to suffering from “schizophrenia.” These encounters appeared designed to elicit false or coerced statements supporting long-standing defamatory claims about my mental health that go all the way down to early childhood.

Given her employment within the Van Nuys Courthouse, her direct property connection to my residence, and her repeated personal interactions, I believe Ms. Wollman has exerted improper influence over judges, clerks, defense attorneys, and prosecutors through misinformation and professional relationships. This pattern is further supported by online statements attributed to Jay Pilchick, the father of my sister-in-law Jennifer Pilchick-Perelman, himself a court reporter in Florida, and by Jennifer Pilchick Perelman, a political attorney who has twice run for Congress against Debbie Wasserman Schultz. In those posts, she stated to a political colleague that “Kevin needs to be deemed crazy.” Together, these facts demonstrate a larger network of personal and professional conflicts that have materially compromised my right to my freedoms starting at a very young age and a fair and impartial process, and clearly indicate motive.

Because these failures coincide with community-policing outreach programs administered under Chief Michael Moore and Officer Charles Sean Dinse, I request that the Judicial Council examine whether such programs have been misapplied in ways that encouraged or failed to prevent civilian harassment, judicial bias, or manipulation of proceedings.

Requested Actions

1. Independent review of case records, transcripts, and judicial conduct in B343120 / LA099813 / 3PY03498 / 7VW04099, with attention to bias, suppression of evidence, and improper judicial influence.
2. Examination of the Pitchess motion denials by Judge Gregory A. Dohi concerning Officer Charles Sean Dinse, and related federal records from Rex Schillenberger v. City of Los Angeles.
3. Investigation into potential conflicts of interest involving Debbie Wollman, Jennifer Pilchick-Perelman, and related parties.
4. Recommendations for referral to appropriate judicial oversight or disciplinary bodies where warranted.

This is not an isolated lapse but a long-term pattern of harassment, retaliation, and denial of constitutional protections, during which I have repeatedly been told that I am “not allowed to tell anyone what is going on.” This began after I started asking questions to Michael Patrick Huntley in 2001, when I began uncovering the coordinated actions taking place around me.

I urge the Judicial Council to review this matter with impartiality, independence, and urgency.

Thank you for your time and attention. Please acknowledge receipt and advise of any next procedural steps.

Respectfully,

Kevin Perlman

To:
Office of the State Public Defender (OSPD)
770 L Street, Suite 1000
Sacramento, CA 95814

From:
Kevin Perlman
26500 Agoura Rd, Suite 102
Calabasas, CA 91302
Phone: (312) 259-3686

Date: 10/20/2025

Subject:
Formal Request for Intervention — Denial of Effective Counsel, Police & Judicial Misconduct, and Three Unlawful Trials

Office of the State Public Defender (OSPD)

Kevin Perlman
26500 Agoura Rd, Suite 102
Calabasas, CA 91302
Phone: 312-259-3686

Date: 10/20/2025

To:
Office of the State Public Defender (OSPD)
770 L Street, Suite 1000
Sacramento, CA 95814

Subject: Formal Request for Intervention — Denial of Effective Counsel, Police & Judicial Misconduct, and Three Unlawful Trials

Related Case and Appeal Numbers:
– Appeal: B343120
– Superior Court Case: LA099813
– Associated Cases: 3PY03498, 7VW04099

Dear Office of the State Public Defender,

For more than two decades I have been met with consistent and unwarranted hostility from individuals within law enforcement, the courts, and community-policing networks. In extremely large circles, From the outset, the conduct has not been isolated or coincidental—it has followed a continuous pattern of intimidation, reversed reporting, and retaliation. Despite my repeated efforts to seek help through proper legal and administrative channels, my attempts to report crimes or defend myself have been met not with protection, but with further hostility and prosecution. I trace these events down to early childhood.

By 2008, this hostility had become overtly threatening. While peacefully walking at a public park and filming a fire truck roughly one hundred yards away out of curiosity, LAPD officers on scene threatened my life, stating on video, “We’re watching you, Perelman.” This incident demonstrated that the targeting extended directly from law enforcement personnel themselves, well before the later prosecutions and community-based harassment escalated.

This pattern continues where ever I am, today. As recently as 2025. I have been subjected to further unlawful proceedings in which I was again denied proper legal representation. Despite repeated requests for conflict-free counsel, I was assigned attorneys who ignored exculpatory evidence and refused to raise clear procedural and constitutional violations. These same issues persist in my ongoing appeals, where my filings have been disregarded and my ability to present a full record continues to be obstructed.

I respectfully request urgent review and intervention in my matters due to repeated violations of my constitutional rights—specifically the right to effective assistance of counsel and a fair trial. Over the past several years I have been subjected to three trials that were unlawful, together with judicial and law-enforcement conduct that has undermined due process and equal protection.

For more than two decades—since 2001—I have faced escalating harassment and intimidation that began with death threats from my former business partner, Mike Huntley, who befriended me when I was fourteen. Since then, I have endured a sustained pattern of stalking, provocation, defamation, and fabricated accusations. The overall pattern has repeatedly conveyed the message—directly and indirectly—that “the judicial system is being used against me” rather than to protect me. The incidents described here represent only a few examples of what I have endured finding out, in 2001.

Despite hundreds of police reports and extensive video documentation, law-enforcement agencies have consistently refused to investigate or protect me. Internal Affairs has repeatedly received detailed complaints with evidence over the years, yet either declined to act or issued watered-down findings. Of particular concern are Officer Toro, who made statements interpreted as threats toward me and my studio photography work, stating, “If you ever take a picture of a person, I will exercise the law in my own way,” and Lead Officer Charles Sean Dinse of the LAPD Topanga Division, whose conduct was the subject of prior federal civil litigation in Rex Schillenberger v. City of Los Angeles involving similar allegations of misconduct and riling community harassment groups against other victims such as myself. When I filed a Pitchess motion seeking disclosure of Officer Dinse’s disciplinary and complaint history to demonstrate relevance and pattern, Judge Gregory A. Dohi refused to grant the motion in regards to Charles Sean Dinse, preventing access to records that could have established credibility issues and prior misconduct. Public records also show that Chief Michael Moore and Officer Dinse have been named in related actions. I ask that your Office review those records to determine whether any conflict, pattern of behavior, or departmental protection relevant to my situation exists.

One of the many more aggressive events was a month after a prior confrontation in which a man in the surrounding complex, handling a large dog threatened my life, stating words to the effect of “You’d better accept what’s going on or it’s going to get a lot worse for you.” They had a problem with me taking walks, getting fresh air, and exercise. On the later occasion, I walked outside my residence and discovered my vehicle had been vandalized: the words “Penal Code 187” were written on the car, objects were glued to its surface, and a single glove was left on it while nearby individuals made remarks referencing the O.J. Simpson case. I immediately called the police to report the vandalism and threatening language directed at me and waited outside for officers to arrive. While waiting, the same man emerged with his girlfriend and the same dog, initiated a loaded conversation, and as I was walking away it appeared the dog was trained to attack on cue, and the girl started punching me from behind and trying to steal the camera that I was documenting the car damage with. Causing severe injuries to my leg. The animal’s behavior suggested formal training, possibly police-level training, although I cannot verify that within this correspondence. These incidents were documented with photographs and video, yet no substantive investigation or protective action followed. The entire incident, is on video, like so many others and provided to Detective Angela Stewart and Detective Shapiro, of the LAPD Topanga Division in Los Angeles, California, was provided with hospital reports and photographs documenting my leg injuries. Despite this clear evidence, she stated that I suffer from mental illness and that the incident had not occurred. Prosecutor Karine T. Phillips later claimed in court that “Kevin is trying to force cards on people,” when in reality, as shown on video, the dialogue was simply: “Would you like a card?” — “Oh, never mind, you already have one.” In several instances across different reports, I have observed that when I called police to report crimes committed against me, the reporting process appeared to be reversed—resulting in criminal allegations filed against me rather than against those responsible for the underlying acts. Several of the individuals involved appeared connected with neighborhood or “community-policing” activities and acted as though they were empowered by law enforcement to intervene or intimidate. I respectfully request that these events, and the handling of the related police reports and subsequent charges, be reviewed in detail to determine why no proper investigation occurred and whether any link exists between these individuals and community-policing programs operating under the Los Angeles Police Department.

Another serious example occurred around 2017, when Bailey Bernard followed me home from Warner Center Park, a public park where I have repeatedly faced unwarranted hostility and daily provocations from individuals with no legitimate reason to interfere with me—other than participation in organized hate-based angry mobs expressing animosity through statements such as “Your kind isn’t welcome here” and we don’t want you here or anywhere else. During that period, I was also subjected to explicit racial threats, including “No relaxing for you, n**r,” and other intimidating remarks clearly intended to provoke confrontation. As I entered the gate to my townhouse complex, Bailey Bernard asked, “Is this where you live?” and struck the keys from my hand, physically assaulting me. I immediately called 9-1-1 and later went to the police station to file a report. Instead of investigating the assault, LAPD filed assault charges against me.

During the subsequent trial, Prosecutor Karine T. Phillips falsely stated that I had never called 9-1-1, and Defense Attorney Seymour Amster—who could have easily obtained the 9-1-1 call records proving otherwise—refused to do so. His refusal mirrored his handling of other exculpatory evidence, including the 2017 parking citation personally issued to me by witness and arresting officer, Lead Officer Charles Sean Dinse of the LAPD Topanga Division, just two weeks before I took the stand in that same trial.

Toward the end of those proceedings, Defense Attorney Seymour Amster remarked, “You’re brilliant; this is about mental illness,” referencing mental-illness watch lists in a way that appeared intended to frame the situation rather than address the facts. There has never been any legitimate mental-health basis for such statements, other than unverified claims from an angry family attempting to manipulate outcomes. Rather, this language has been used to portray me as mentally ill in order to discredit my testimony and minimize documented misconduct. This tactic, coupled with reversed police reports and suppression of evidence, has contributed to a continuing pattern of institutional retaliation and defamation that persists to this day.

Another area of serious concern involves Court Reporter Debbie Wollman of the Van Nuys Courthouse, who for approximately twenty years owned the townhouse directly adjoining mine—sharing a common wall—but never resided there. This property ownership presents a clear conflict of interest, as Ms. Wollman works at the same courthouse where many of my hearings and trials have taken place. The property has appeared online in connection with “Going Vertical, Inc.”, a corporate name previously proposed by Mike Huntley, which raises additional questions about potential judicial or professional impropriety linked to that location. Notably, Ms. Wollman sold the adjoining property shortly after I was released from custody, a timing that further raises questions regarding possible undisclosed relationships or conflicts connected to that residence and her position at the courthouse.

Ms. Wollman appears in at least three videos: one from 2017, in which she tells me that I am “not allowed at the courthouse,” during my trial, and two later encounters in 2025, shortly after I was released from custody and again within the following month, where she approached me unsolicited—saying “no hard feelings” as if we were in some form of personal competition—and insisting that I “admit” to suffering from “schizophrenia.” These encounters appeared designed to elicit false or coerced statements supporting long-standing defamatory claims about my mental health that go all the way down to early childhood.

Given her employment within the Van Nuys Courthouse, her direct property connection to my residence, and her repeated personal interactions, I believe Ms. Wollman has exerted improper influence over judges, clerks, defense attorneys, and prosecutors through misinformation and professional relationships. This pattern is further supported by online statements attributed to Jay Pilchick, the father of my sister-in-law Jennifer Pilchick-Perelman, himself a court reporter in Florida, and by Jennifer Pilchick Perelman, a political attorney who has twice run for Congress against Debbie Wasserman Schultz. In those posts, she stated to a political colleague that “Kevin needs to be deemed crazy.”

Together, these facts demonstrate a larger network of personal and professional conflicts that have materially compromised my right to my freedoms, and a fair and impartial process and clearly indicate motive.

Because these failures coincide with community-policing outreach programs administered under Chief Michael Moore and Officer Charles Sean Dinse, I request that any review examine whether those initiatives have been misapplied in ways that encouraged or failed to prevent civilian harassment.

Court-appointed counsel across these cases ignored exculpatory evidence and discouraged filings that could have exposed this misconduct. As a result, I have never received conflict-free or effective representation.

Requested actions
1. Comprehensive review of case files and transcripts for B343120 / LA099813 / 3PY03498 / 7VW04099, focusing on ineffective counsel, suppression of evidence, and reversed reporting.
2. Independent inquiry into law-enforcement and Internal-Affairs handling of my complaints and the reversal of charges.
3. Assignment of conflict-free counsel outside local networks potentially influenced by the parties named above.
4. Guidance on filing formal Sixth- and Fourteenth-Amendment claims and pursuing post-conviction relief.

This is not an isolated lapse but a long-term pattern of harassment, retaliation, and denial of constitutional protections, during which I have repeatedly been told that I am “not allowed to tell anyone what is going on.” Especially finding out in 2001 and asking questions to Michael Patrick Huntley. I urge your Office to review this matter with impartiality and urgency.

Thank you for your attention. Please acknowledge receipt and advise next steps.

Respectfully,
Kevin Perlman

Evidence Summary & Timeline Overview

Kevin Perelman
26500 Agoura Rd, Suite 102 Calabasas, CA 91302 • (312) 259-3686

Purpose

This summary provides a concise timeline and representative examples of incidents, reports, and filings documenting ongoing harassment, reversed reporting, and denial of effective legal representation.
These entries represent only a small portion of the countless overwhelming events that have occurred since finding out what was going on in 2001. Complete video, photographic, and document archives are available upon request.

Timeline of Representative Events

Year / Period	Event Description	Individuals / Agencies Involved
2001 – Present	Beginning of a long-term pattern of stalking, harassment, and defamation following death threats from business partner Mike Huntley, including early efforts to provoke, isolate, and incite public hostility through organized civilian groups.	Huntley ; LAPD ; civilian networks
2008	LAPD officers threaten Kevin’s life while he was walking at a public park and filming a fire truck approximately 100 yards away out of curiosity. On video, one officer can be heard saying, “We’re watching you, Perelman.” This demonstrates early, direct intimidation by law enforcement for lawful conduct.	LAPD officers ; LAPD Topanga Division
2013	Officer Toro issues threats regarding photography work, stating, “If you ever take a picture of a person, I will exercise the law in my own way.” Internal Affairs received multiple reports but failed to take action or accurately record the complaints.	LAPD Topanga Division / Internal Affairs
2017	Bailey Bernard follows Kevin home from Warner Center Park, verbally provokes and assaults him. When Kevin reports the crime, LAPD reverses the report and charges him with assault instead. Prosecutor Karine T. Phillips falsely claims no 911 call was made, and Defense Attorney Seymour Amster refuses to obtain 911 records or present exculpatory evidence—part of a broader recurring pattern throughout multiple cases.	Bernard ; LAPD ; Phillips ; Amster
2017 (Pre-Trial)	Lead Officer Charles Sean Dinse personally issues a parking citation two weeks before testifying in the same case. A Pitchess motion filed for Dinse’s disciplinary and complaint history is denied by Judge Gregory A. Dohi, blocking access to potentially exculpatory information. Dinse was also previously named in federal case Rex Schillenberger v. City of Los Angeles involving similar allegations of misconduct.	Dinse (LAPD Topanga Division) ; Judge Dohi ; City of Los Angeles
2017 (Trial Phase)	Defense Attorney Seymour Amster references “mental illness watch lists” to reframe the case and discredit Kevin, using psychiatric labeling as a tactic to undermine testimony and shift focus away from factual evidence.	Amster ; Prosecutor Phillips
2019 – 2020	Vehicle vandalized (“Penal Code 187” written on car, objects glued, glove left as symbolic threat). Subsequent dog attack causes severe leg injury. Evidence provided to Detectives Angela Stewart and Shapiro (LAPD Topanga Division) along with hospital reports and photos. Detective Shapiro dismisses the incident, claiming Kevin “suffers from mental illness” and that the event did not occur. Prosecutor Karine T. Phillips later misrepresents video dialogue to imply aggression.	Unidentified male with dog ; Det. Stewart ; Det. Shapiro ; Phillips ; LAPD
2020 – 2025	Court Reporter Debbie Wollman (Van Nuys Courthouse) owned the townhouse adjoining Kevin’s home for ~20 years without residing there. Property linked online to “Going Vertical, Inc.”, a corporate name previously proposed by Mike Huntley. Wollman sold the adjoining property shortly after Kevin’s release from custody, raising further questions about timing and potential conflict. She appears in videos telling Kevin he is “not allowed at the courthouse” (2017) and later approaching him (2025) to elicit a false “admission” of mental illness. Jennifer Pilchik-Perelman (Florida attorney and two-time congressional candidate against Debbie Wasserman Schultz) and her father Jay Pilchik (publicly stating “Kevin needs to be deemed crazy”) help propagate defamatory narratives.	Wollman ; Pilchik family ; Huntley ; Van Nuys Courthouse staff
2023 (Trial & Appeals)	Renewed Pitchess motion regarding Officer Dinse’s prior conduct again obstructed. The same Judge Gregory A. Dohi denies discovery access, continuing the suppression of potential exculpatory evidence despite prior misconduct being documented in Rex Schillenberger v. City of Los Angeles.	Judge Dohi ; LAPD Legal Division ; Public Defenders
2023 – Present	Continued unlawful proceedings, denial of conflict-free counsel, and obstruction of appeals (B343120 / LA099813 / 3PY03498 / 7VW04099). Persistent reversal of police reports, judicial hostility, and refusal to address constitutional violations.	Public Defenders ; Appellate Courts ; LAPD liaisons
Ongoing (2001 – 2025)	Persistent community-based surveillance, defamation, and provocation linked to community-policing programs operating under Chief Michael Moore and Officer Charles Sean Dinse. No verified oversight or corrective action to date.	LAPD Administration ; Chief Moore ; Dinse ; Community Policing Units

Supporting Materials (Available Upon Request)

• Certified copies of police reports and Internal Affairs correspondence
• Court transcripts and appeal filings for all listed cases
• Video and photo archives (totaling multiple terabytes)
• Certified mail receipts and complaint acknowledgments
• Federal case records (Rex Schillenberger v. City of Los Angeles)
• Documentation of Debbie Wollman property ownership and related videos

Summary Statement

These entries represent only a small sample of a broader, ongoing pattern of harassment, retaliation, and systemic denial of due process spanning more than two decades. They collectively demonstrate consistent failures by law enforcement, the courts, and public defenders to provide impartial investigation, protection, and representation.

http://www.KevinPerelmanTarget.com

The Right to Proper Council

California Penal Code § 182 – Conspiracy

Summary:

Why is the PERELMAN family FORCING criminal Jewish Lawyers on my with their Judge Friends, Dr Steve Levinson following me to the Car Groups, with his Judicial Family, and Bail Bond friends. In a mass operation to eradicate at all costs with empty label jusitifcatons and the criminal Psychology Community friends?

And a Judicial Aiding and Abetting Crime Ring. This starts at 5 years old.

This law makes it a crime for two or more people to conspire to commit a crime, or to falsely prosecute or frame someone through unlawful means, even if the crime doesn’t actually occur, as long as there’s an overt act taken in furtherance of the conspiracy.

🔧 Key Elements:

To prove a criminal conspiracy under PC §182:

1. Agreement between two or more persons to commit a crime;
2. Intent to commit that crime;
3. An overt act committed by one or more parties to advance the conspiracy.

🧩 How It Applies to Refusal to Impeach Witnesses

If multiple actors (e.g., officers, prosecutors, defense attorneys, or witnesses) are working together to:

• Protect false testimony
• Suppress exculpatory evidence (like stalking video, witness credibility issues, parking ticket timestamp, etc.)
• Refuse to impeach obviously discredited or provable-false witnesses
• Obstruct a fair trial

…and there is clear or circumstantial evidence of coordination or pattern, then it could fall under PC §182 as a conspiracy to obstruct justice, suppress evidence, or even falsely imprison you.

Kevin Perelman

26500 Agoura Rd, Ste 102

Calabasas, CA 91302

312-259-3686

10/17/2025

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA SECOND APPELLATE DISTRICT, DIVISION FOUR

The People of the State of California, Plaintiff and Respondent,

v.

Kevin Perelman,

Defendant and Appellant.

Case No. B343120

MOTION FOR APPOINTMENT OF NEW COUNSEL

(REQUEST FOR SUBSTITUTION OF APPOINTED ATTORNEY)

TO THE HONORABLE COURT OF APPEAL, SECOND APPELLATE DISTRICT:

Defendant and Appellant Kevin Perelman respectfully moves this Court for the

appointment of new appellate counsel. This motion is based on the following grounds:

Right to Effective, Conflict-Free Counsel:

Pursuant to the Sixth Amendment of the United States Constitution and Article I, Section 15 of the California Constitution, “In all criminal prosecutions, the accused shall enjoy the right…to have the Assistance of Counsel for his defence.”

California law requires that appointed counsel must provide effective and conflict-free assistance at all critical stages of the proceedings. (People v. Marsden (1970) 2 Cal.3d 118; California Penal Code § G87.2.)

Grounds for Substitution:

A defendant is entitled to new counsel if there is a conflict of interest, a breakdown in the attorney-client relationship, ineffective assistance, or loss of trust or confidence in current counsel. (See Marsden, supra; People v. Smith (1993) 6 Cal.4th 684, 696; People v.

Ortiz (1990) 51 Cal.3d 975.)

Specific Basis for Request:

Appellant has experienced a breakdown in the attorney-client relationship, “failure to investigate/appellate issues, conflicts of interest, lack of communication, and loss of trust”.

See Attachment Letter:

Request for Hearing:

Appellant requests that the Court conduct a hearing to consider this request for substitution of counsel, as required by People v. Marsden, supra.

WHEREFORE, for the reasons stated above, Appellant respectfully requests:

• • That the Court grant this motion,
  • That new appellate counsel be appointed, and
  • For any other relief the Court deems just and proper. Respectfully submitted,

Kevin Perelman, Appellant

Legal Authority

• • Sixth Amendment, U.S. Constitution; Cal. Const., Art. I, § 15
  • Cal. Penal Code §§ 987, 987.2
  • People v. Marsden (1970) 2 Cal.3d 118
  • People v. Smith (1993) 6 Cal.4th 684, 696–697
  • People v. Ortiz (1990) 51 Cal.3d 975

Letter

To California Appellate Project Refusal Acknowledge My Requests

Kevin Perelman

26500 Agoura Rd, Ste 102

Calabasas, CA 91302

312-259-3686

10/16/2025

California Appellate Project – Los Angeles

Attn: Executive Director Jennifer Peabody (or Supervising Attorney) 520 S. Grand Ave, 4th Floor

Los Angeles, CA 90071 Phone: (213) 243-0300

Fax: (213) 243-0303

Email: Capdocs@lacap.com

Re: Request for Appointment of New Appellate Counsel and Formal Complaint – Case No. B343120

To Whom It May Concern:

I urgently reiterate my request for the appointment of new appellate counsel and submit this formal complaint regarding the ongoing mishandling and oversight of my appeal, Case No. B343120.

Conflict of Interest, Prejudice, and Attorney Selection Concerns

My trial attorney, Shep Alan Zebberman (#155478), was privately retained and provided

ineffective assistance of counsel. My current appellate counsel, Yisrael Gelb (#344924), is a rabbi and presents a clear religious identity. I am Jewish myself, but I have observed a troubling pattern in which nearly all attorneys assigned to me—either by the courts or CAP—share the same tight-knit community affiliation, sometimes with visible religious leadership roles. This pattern raises concerns that attorney selection, rather than being

impartial and neutral, may be influenced by factors risking divided loyalty and bias. I firmly believe that religion and law should remain strictly separate in professional legal

assignment. I request oversight and transparency to ensure fairness and diversity in attorney assignment.

Inexperience of Appointed Counsel

Yisrael Gelb, according to state bar records, has only been licensed for approximately two years. This minimal experience is deeply concerning, as my appeal involves complex

constitutional issues, alleged judicial and prosecutorial misconduct, and a significant

impact on my future. It is simply not appropriate for a case with these stakes to be assigned to an attorney this inexperienced.

Omission from CAP-LA Directory

Upon reviewing the official CAP-LA staff/panel listing (see Attachment 1), I found that Mr. Gelb does not appear as a staff or recognized panel attorney. I respectfully request an explanation of how he was assigned and whether standard CAP-LA procedures have been followed.

Lack of Notice or Communication

For the record, I have never received any official notice, written correspondence, or other communication by mail regarding the appointment or substitution of appellate counsel, relevant deadlines, or any related matters in this case from CAP-LA or the court.

All information I have obtained has come from my own online docket research or direct

inquiry. This highlights a serious breakdown in due process and communication affecting my rights.

CAP-LA Communication (Rick Lennon Email) and Inferred Denial of New Counsel Attachment 2 is an email from Rick Lennon of CAP-LA, dated September 14, 2025. While Mr. Lennon does not expressly deny my request for new counsel, he makes it clear that CAP-LA intends to keep Mr. Gelb on my case despite my repeated, written objections. The substance of the email disregards my concerns about conflict of interest, the importance of habeas expertise, and procedural fairness.

Case Docket Irregularities

Attachment 3 contains screenshots of the state court docket showing a “replace appointed counsel” notice dated 10/15/2025. I was never contacted by a new attorney, no

substitution took place, and there are proofs of service filed with dates set in the future (see Attachment 4). This raises further concerns about transparency, accuracy, and

reliability in my case record.

Systemic Pattern and History in Prior Cases

This is not the first time I have experienced such issues in Los Angeles County. I have had two prior criminal cases—Case No. 3PY03498 and Case No. 7VW04099—where similar problems occurred. Lawyers with community or religious ties, or a disposition toward prejudice or coordinated adverse action, resulted in unfair or ineffective representation. I respectfully submit that these repeated problems indicate a broader, systemic issue with how representation is being assigned and overseen in my matters. (See Attachment 5 for detailed summary.)

Comprehensive Record of Documented Complaints and Habeas Petition

In addition, please see:

• Attachment 6: My initial written request for new counsel (August 4, 2025), which has not been addressed, and a record that an opening statement was filed on 10/13/2025 instead.
• Attachment 7: Statement of Ineffective Assistance of Counsel and Petition for Writ of Habeas Corpus, summarizing my legal arguments and supporting evidence.
• Attachment 8: Ineffective Assistance, Misconduct C Corruption Statement – Trial Judicial Misconduct – Notes, providing additional detail on courtroom and systemic misconduct.

Request for Immediate Action

For all these reasons, I respectfully and urgently request:

• Immediate appointment of new appellate counsel, independent from prior

attorneys, fully vetted, and with no close community or religious ties to previous defenders.

• Written clarification of CAP-LA’s process for assigning Mr. Gelb to my case, why his name does not appear on your staff/panel directory, and what supervisor-level

review (if any) has been conducted.

• Assurance that no actions are taken in my appellate matter until impartial, conflict- free, and sufficiently experienced counsel has been assigned, and a supervisor has confirmed full review and corrective action in my file.

Thank you for your immediate attention. Please ensure this letter and all supporting attachments are made part of my official appellate file. I respectfully request a formal, written response as soon as practicable.

Attachments:

1. CAP-LA Attorney/Staff Directory, October 2025 printout
2. Email from Rick Lennon (CAP-LA), September 14, 2025
3. Appellate court docket screenshots (“replace appointed counsel”)
4. Proof of Service Date 10/20/2025 instead of 10/15/2025 inconsistencies
5. Criminal cases (now including 3PY03498 and 7VW04099)
6. Prior request for reassignment of appellate counsel (August 4, 2025)
7. Statement of Ineffective Assistance of Counsel and Petition for Writ of Habeas Corpus
8. Ineffective Assistance, Misconduct C Corruption Statement – Trial Judicial Misconduct – Notes

Sincerely,

Kevin Perelman

Attachment 1

CAP-LA Attorney/Staff Directory, October 2025 printout

Attachment 2

Email from Rick Lennon (CAP-LA), September 14, 2025

Attachment 3

Appellate court docket screenshots (“replace appointed counsel”)

Attachment 4

Proof of Service Date 10/20/2025 instead of 10/15/2025 inconsistencies

Attachment 1

criminal cases (now including 3PY03498 and 7VW04099)

Van Nuys Courthouse Cases with Judicial Misconduct: criminal cases:

3PY03498

7VW04099

Attachment 6

Prior request for reassignment of appellate counsel (August 4, 2025)

To

California Appellate Project

Phone: Phone: (213) 243-0300

Fax: (213) 243-0303

August 4, 2025

Email:Capdocs@lacap.com AppellateBranch@pubdef.lacounty.gov

Adress: 520 South Grand Avenue, 4th Floor Los Angeles, CA 90071

To Whom It May Concern:

The People v. Kevin Perelman, Case No. B343120 Court of Appeal, Second Appellate District, Division Four

Dear Supervising Attorney,

I am writing to formally request the reassignment of new appellate counsel in my case, The People v. Kevin Perelman, Case No. B343120, currently before the Court of Appeal, Second Appellate District, Division Four.

I have serious concerns about a potential conflict of interest that could affect my representation. While my current appointed appellate attorney has not acknowledged any conflict, I feel there is a strong likelihood of one due to community affiliations and the circumstances of my case. Both my previous trial attorney and the current appellate attorney are members of the same small, close- knit community (the Jewish community), and my current appellate attorney is also a Rabbi. I am concerned these community connections may create both the appearance and reality of divided loyalty, and possibly an unwillingness to fully pursue claims involving another member of the same community.

Additionally, I am concerned about my appointed appellate attorney’s limited experience (approximately two years since passing the bar), which I believe is insufficient for a case of this seriousness and complexity. As an inexperienced lawyer, he may not possess the necessary knowledge or familiarity with habeas corpus proceedings. He has told me directly that he believes he is limited to what is included in the trial transcripts and docket, even though filing a writ of habeas corpus is often necessary to address ineffective assistance of counsel based on facts outside the transcript and docket.

It is especially important to note that my case may also involve significant judicial and prosecutorial misconduct. My concerns include, but are not limited to, fraudulent police reports, improper investigative practices, potential bias or unfair treatment from both the prosecution and the trial court, and witnesses conspiring with police in illegal operations. I am deeply concerned that these issues have substantially impacted the integrity and fairness of my trial, and that they warrant careful and impartial review on appeal. I believe my current appellate counsel is not adequately positioned, either in terms of experience or independence, to thoroughly investigate and argue these matters, especially where those issues involve or are intertwined with claims of ineffective assistance of counsel.

For these reasons, I respectfully request that a new appellate attorney —one with no prior professional or personal association with my previous legal counsel, not a member of the same religious or social network, and who is highly experienced with both direct appeals and habeas corpus claims—be assigned to handle my appeal. It is critically important to me that my appellate representation is impartial and fully qualified to pursue all necessary legal remedies, including direct challenges to judicial or prosecutorial misconduct and the involvement of witnesses in illegal conduct.

I trust that you will carefully review my concerns and take timely action to ensure fair representation as required by law. Thank you for your attention to this urgent and sensitive matter.

Sincerely, Kevin Perelman

Kevin Perelman

Appellant

26500 Agoura Rd, STE 102

Calabasas, Ca 91302

312-259-3686

Kevin@KevinPerelman.com

Attachment 7

Statement of Ineffective Assistance of Counsel and Petition for Writ of Habeas Corpus

To

California Appellate Project

Phone: Phone: (213) 243-0300

Fax: (213) 243-0303

Email:Capdocs@lacap.com AppellateBranch@pubdef.lacounty.gov Adress: 520 South Grand Avenue, 4th Floor Los Angeles, CA 90071

To Whom It May Concern:

The People v. Kevin Perelman, Case No. B343120 Court of Appeal, Second Appellate District, Division Four

Petition for Writ of Habeas Corpus

Ground: Ineffective Assistance of Counsel — Presentation of New and Extrinsic Evidence

1. Petitioner’s Claim: Ineffective Assistance of Counsel

Petitioner, Kevin Perelman, respectfully seeks habeas corpus relief based on egregious ineffective assistance of counsel by Shep Zebberman, as demonstrated by facts both in and outside the trial record. This claim is supported by the following:

1. Legal Standard (Strickland v. Washington) Relief is warranted when:
   1. Counsel’s performance was constitutionally deficient;
   2. There is a reasonable probability that, but for counsel’s unprofessional errors, the result would have been different.
2. Statement of Facts C New Extrinsic Evidence

Discriminatory and Prejudicial Conduct

• • • Shep Zebberman made prejudiced statements and failed to advocate for me due to personal and community bias, as described in my declaration and corroborated by third-party witnesses and community records.

Failure to Investigate, Prepare and Present Defense

• • • Did not review or present extensive video evidence of mobbing, vandalism, and ongoing harassment in conspiring methods and events with LAPD.
    • Refused to meet with me to discuss my side of events, relying solely on prosecution evidence.

Failure to Investigate or Call Available Witnesses

• • • Never investigated, interviewed, or subpoenaed witnesses who could have testified on my behalf, including:
• Eyewitnesses to harassment, vandalism, and provocation;
• Neighbors and community members familiar with false allegations by Officer Dinse, Terrance Scroggins, Pedram Espinoza, and others;
• Victims of Officer Dinse’s similar misconduct (e.g., federal lawsuit by Rex Schillenberger);
• Experts in police procedure and community mobbing.

Failure to hire or consult with any private investigator who could have

interviewed witnesses, gathered additional exculpatory statements, or tracked social media campaigns against me.

• • Evidence: Declarations from available witnesses, statements from those never

contacted by defense, my own sworn declaration, investigator reports (if available), and a list of potential witnesses with what their testimony would have shown.

• • Failure to introduce events of police harassments, intimidation, as well as witness harassment, intimidation, before and during the trial.

Failure to File Key Motions and Argue Self-Defense

• • • Did not file a Pitchess motion against Officer Dinse, despite his documented history of similar misconduct.
    • Refused to argue self-defense even with documentary/video evidence of years-long provocation by community and police.
    • Did not challenge fabricated restitution claims or expose documented blackmail efforts by prosecution witnesses. Working with their friends in the court house to pose as FBI agents for intimidation.

Conflict of Interest s Coercion Toward Insanity Plea

• • • Prioritized relationships with trial judges over client defense.
    • Pressured me to accept Not Guilty by Reason of Insanity (NGI) without legal/medical basis.

Failure to Seek Change of Venue or Protect Against Community Harassment

• • • Ignored repeated, documented attempts by Officer Dinse and neighborhood watch to incite community bias, including via Facebook and public statements.
    • Did not move to change venue despite mass prejudice, nor did he advise or assist with seeking restraining orders against harassers.

Failure to Impeach Prosecution Witnesses

• • • Did not challenge (impeach) perjured or contradictory testimony from key

witnesses, and did not present readily available impeachment material (videos, letters, reports).

Failure to Protect Defendant from Direct Courtroom Intimidation

• • • Did not object or seek mistrial when individuals impersonating FBI agents appeared in the courtroom with Prosecutor Orbelli to intimidate me in the

presence of the judge and jury—egregious misconduct designed to prejudice my defense, create an unfair environment, and reinforce false government narratives.

• • • Failed to raise the issue of prosecutorial collusion with these individuals and did not seek judicial intervention or police report to expose this unlawful intimidation tactic.
    • Evidence: My declaration, affidavits from anyone who witnessed or heard about the “FBI” presence, court security reports, and any correspondence with court staff about these incidents.

G. Additional Examples of Evidence Outside the Trial Record

• Newly available police records or Bar complaints showing patterns of misconduct not included in trial evidence.
• Social media posts by Officer Dinse or others, including deleted/archived content recovered through subpoenas.
• Expert opinions now available but not sought by defense (e.g., on police procedure, mobbing, prejudice).

1. Prejudice: Strickland Standard Satisfied Because of the above errors:

• The jury never heard or saw critical exculpatory evidence or witness testimony that would have undermined the prosecution’s case.
• Lack of a private investigator, lack of witness interviews, and failure to object to intimidation fundamentally denied me a fair trial.
• The outcome would likely have been different had defense counsel met even minimal professional standards.

1. Prayer for Relief and Request for Evidentiary Hearing

Petitioner respectfully requests:

• 1. An order to show cause and/or evidentiary hearing to receive this new, extrinsic evidence.
  2. Vacation of conviction and/or outright dismissal due to cumulative constitutional error.

1. Evidence to be Attached (Example)

• Declaration of Kevin Perelman (listing all witnesses I requested or identified, complaints re: FBI impersonators, failure to investigate)
• Declarations/affidavits from uninvestigated witnesses, neighbors, and potential experts
• Affidavit from (or record of attempted contact with) a private investigator, if available
• Videos and audio not introduced at trial
• Screenshots/archived copies of relevant Facebook/social posts
• Security/court incident reports regarding presence of FBI agents or intimidation efforts
• Insurance, restitution, and any financial records relating to blackmail/extortion claims
• Copies of relevant Bar complaints, police records, or civil complaints

Attachment 8

Trial Judicial Misconduct – Notes

To

California Appellate Project

Phone: Phone: (213) 243-0300

Fax: (213) 243-0303

Email:Capdocs@lacap.com AppellateBranch@pubdef.lacounty.gov Adress: 520 South Grand Avenue, 4th Floor Los Angeles, CA 90071

To Whom It May Concern:

The People v. Kevin Perelman, Case No. B343120 Court of Appeal, Second Appellate District, Division Four

Ineffective Assistance of Counsel and courtroom misconduct – Shep Zebberman Specific Accusations:

• Discriminatory and Prejudicial Comments
• Sheps Statement to me, right before the verdict “You might get away with this” Showing from day one, he was acting as a judge, not a Lawyer. And was never going to represent me fairly and was involved in a conspiracy to lock me away no matter how innocent. No matter how much proof. He wasn’t even going to try to prove my innocence.
• Everything asked he give an opposite answer, and disinformation, showing anger. I asked about change of venue. like change of venue, he lied stating their was not

grounds for. While was friends with a lot of the Judges. Being provoked and harassed by witness Terrance Scroggins during trial. Would not help with filing restraining

orders or use the information to show in the court at any time that Terrance was always the aggressor or impeach the witnesses properly jumping from lawyer to lawyer.

– Penal Code § 147: Willful deprivation of a client’s rights

Failure to Investigate/Prepare/Defend

• Did not review Kevin’s exculpatory video evidence or ask for Kevin’s version of events. – Relied on fabricated reports and prosecution narrative. – Penal Code § 1054.G: Failure to seek or present exculpatory evidence

Failure to File Key Motions

• Judge Dohi, refused to file Pitchess motion for LAPD Officer Charles Sean Dinse, despite Dinse’s federal lawsuits for similar behavior. – Would not request change of venue or move for mistrial, nor file dismissal. Even with the events happening in the court room – Penal

Code § 1054.5: Withholding of motions/evidence

Conflict of Interest

• Admitted being friends with Judge Gregory A. Dohi and Judge Stephen Marcus, failed to zealously advocate for client. – Potentially took $50,000 under false pretenses (with

influence from Arnold Silber, Kevin’s stepfather). – Penal Code § 182(a)(5): Conspiracy to obstruct justice

Coercion Toward Insanity Plea (NGI)

• Tried to pressure client to plead NGI to “get you out of this,” abusing attorney’s

power/trust. Stating “I can get you out of this” I know some Psychology People – Business s Professions Code § 6068: Duty to act with honesty and loyalty

Refusal to Provide Self-Defense Argument

• Refused to present documented mobbing/stalking history; said self-defense not possible for vandalism despite clear evidence of gangstalking and conspiracy amongst mass

stalking groups with LAPD with an Agenda to setup or frame the defendant. – Penal Code § 6G2-6G4: Legitimacy of self-defense argument

Judicial Corruption s Misconduct Specific Accusations:

• • Bias and Prejudice
• Judge Stephen Marcus: “I’ll squeeze you out of your place.”
• Judge Gregory A. Dohi: Fabricated mental health diagnoses, belittled and intimidated

defendant (“Come on down!”) treating court rooms and trials like fun game shows, denied defense motions for Pitchess; colluded in systemic prejudice.

• Penal Code § G6 s G6.5: Judicial officers acting corruptly, maliciously, or with conflict of interest

Van Nuys Court Reporter who owns property adjoining my wall Misconduct – Debbie Wollman

• Spread false rumors about Kevin’s mental health to court staff and judges; owned

property adjoining defendant (conflict of interest). – Omitted critical exculpatory phrases from transcripts (e.g., “Every Miata is modified”). – Penal Code § 134: Preparing false

evidence (tampered transcript) – Penal Code § 182: Conspiracy

Police Corruption – Officer Charles Sean Dinse Specific Accusations:

• • History of Lawsuits and Misconduct
• Used Facebook to incite neighborhood harassment against Kevin; earlier federally sued by Rex Schillenberger.
• Publicly posted “How do we FORCE people into mental facilities,” inciting community intimidation/hate/Stalking groups.
• Penal Code § 182: Conspiracy to violate civil rights
• Penal Code § 135: Destroying/concealing evidence

Fabrication of Claims and Evidence

• Lied about Kevin following him with Prosecutor Orbell to use as amo for increased

sentencing, staged incidents to provoke legal trouble. – Seized art computer (falsely called a “hard drive”), made misleading claims about data. – Penal Code § 118: Perjury – Penal Code § 141: Planting/tampering with evidence

Intimidation and Collusion

• Orchestrated use of “fake FBI agents” to intimidate Kevin in courtroom right before trial day. – Colluded with Prosecutors Lisa Orbelli and Detective Ruiz, and Charles Sean Dinse.
• Penal Code § 136.1: Witness/victim intimidation – Penal Code § 182: Conspiracy

Witness and Community Misconduct

Specific Accusations:

• • Terrance Scroggins (Neighbor/Witness):
• Engaged in continuous harassment/provocation before and during the trial(240+ videos), staged vandalisms with neighbors, Provokings, submitted false restitution claims (colluded with USAA Insurance to repaint entire car, then sought extra $5,000 after USAA paid for

repairs).

• Left blackmail threats in writing demanding DIRECT restitution money.
• Penal Code § 518: Extortion
• Penal Code § 118: Perjury

Pedram Espinoza (Neighbor/Witness):

• Provided knowingly false testimony about his time at the property and his encounters with Kevin. – Penal Code § 118: Perjury. No impeaching the witness with Pedram on video stating I’m not allowed at my townhouse complex. Or that I take pictures of kids. Showing he’s defaming my name and has motive to get rid of me. Shep kept the argument in the

context to make it look like I was loitering around his house, in the common areas of our complex. A Juror had to ask the Judge how long I lived their he picked up one the one sided stories.

Community Members (“Yosi,” Jason Ryan Fishman, etc.):

• Participated in organized surveillance/harassment; repeated slander (“not a real Jew,” “mentally ill”), acted at direction of Officer Dinse and neighborhood watch. – Penal Code §

653.2: Electronic/cyber harassment – Penal Code § 182: Conspiracy to harass. Showing linked events within the Jewish Community.

Prosecutorial Misconduct Specific Accusations:

• Lisa Orbelli s Detective Ruiz (Prosecutors):
• Collaborated with police and witnesses to create “incidents” for prosecution; made false claims and permitted intimidation tactics in and around the courthouse.
• Permitted/introduced false evidence, allowed staged intimidation (fake FBI agents and courthouse staff).
• Penal Code § 118: Subornation of perjury
• Penal Code § 182: Conspiracy
• Penal Code § G6.5: Misconduct by officers of the court

Transcript, Records, and Restitution Tampering Specific Accusations:

• • Omitted or altered evidence/testimony in trial transcripts (Debbie Wollman).
  • Docket/minute orders contained unexplained errors or clerical manipulation (split sentence, “no probation” issues), possibly at the direction of corrupt clerks and neighbor/court reporter Debbie Wollman.
  • Restitution awarded based on fraudulent insurance claims and blackmail tactics (Terrance Scroggins).
  • Penal Code § 134: Preparing false documentary evidence
  • Penal Code § 115: Filing false instruments

Overarching Constitutional and Civil Rights Violations Specific Accusations:

• • Constitutional:
• Denial of due process (U.S. Const. Amend. XIV)
• Denial of effective assistance/counsel (U.S. Const. Amend. VI; Strickland v. Washington)
• Denial of fair trial and equal protection (California Const. Art. I, §§ 7, 15)

Pattern of Systemic Government Abuse:

• Collusion among judges, defense, prosecutors, police, and community.
• Tampering, intimidation, and long-term targeting that makes fair retrial impossible.
• Penal Code § 182: Criminal conspiracy
• Civil Remedies: 42 U.S.C. § 1983 (federal civil rights suit for deprivation of rights under color of law)

Judicial Corruption—Grounds for Dismissal Overlooked

• • Repeated Judicial Bias:
• Judge Stephen Marcus made overtly hostile comments toward Defendant (“I’ll squeeze you out of your place”), demonstrating clear personal animosity and prejudice contrary to impartial adjudication required by law.
• Judge Gregory Dohi fabricated “mental illness” labels for Defendant with no clinical basis, belittled Defendant during proceedings, and denied valid defense motions (e.g., Pitchess motion for Officer Dinse), demonstrating pattern of prejudiced rulings.

Legal Basis: Judicial bias and partial are grounds for mistrial or dismissal:

• *Caperton v. A.T. Massey Coal Co.*, 556 U.S. 868 (2009) (extreme judicial bias may violate due process).
• Cal. Penal Code § 96, § 96.5 (corrupt conduct by judicial officers).

Court Reporter Misconduct s Transcript Tampering:

• Debbie Wollman, with a direct conflict of interest, fabricated negative mental health rumors about Defendant to judges and staff, and altered the official record (omitting

exculpatory testimony such as “Every Miata is modified”). Legal Basis: Cal. Penal Code § 134 (preparing false evidence), § 182 (conspiracy to pervert justice).

Police Officer Corruption—Grounds for Dismissal Overlooked

• • Officer Charles Sean Dinse’s Documented Corruption:
• Used his Facebook account to incite community mobbing (“How do we FORCE people into mental facilities”), was previously federally sued for similar actions.
• Lied under oath about Defendant following him with Prosecutor Orbelli for increased

sentencing, fabricated incidents, and seized Defendant’s computer misrepresenting both its contents and evidentiary value.

• Regularly engaged in provocation and intimidation designed to escalate Defendant’s legal peril.

Legal Basis:

• Cal. Penal Code § 118 (perjury), § 141 (evidence tampering), § 182 (conspiracy), § 147 (officials depriving rights).
• Cal. Evidence Code § 1043 et seq. (Pitchess motion—officer history of dishonesty/abuse is grounds for discovery, impeachment, and, where egregious, dismissal).

Prosecutorial Misconduct—Compelling Grounds for Dismissal Ignored

• • Fabrication, Coll, and Use of False Evidence:
• Prosecutors Lisa Orbelli and Detective Ruiz collaborated with Dinse, Scroggins and others, knowingly presenting false or uninvestigated claims to the court.
• Prosecutors enabled and facilitated courtroom intimidation—including the appearance of people posing as FBI agents during trial—creating an atmosphere of threat and

unlawfulness.

• Prosecutors injected irrelevant hearsay and prejudicial evidence into the record, repeatedly straying from the charges to paint Defendant as dangerous or unstable, manipulating judicial perception and deliberation.

Legal Basis:

• *People v. Batts* (2003) 30 Cal.4th 660, 693 (dismissal appropriate in egregious government misconduct).
• Cal. Penal Code § 118 (subornation of perjury), § 182 (conspiracy), § 96.5 (prosecutorial misconduct).

Admission of Hearsay/Irrelevant Allegations:

• Prosecutors repeatedly introduced and relied on one sided prejudicial statements and hearsay incidents—statements, rumors, alleged threats, and unrelated community disputes—irrelevant to the charged offenses, used solely to inflame and manipulate the judge and jury. – Defense counsel failed to object or move to strike these prejudicial and

improper references, compounding the miscarriage of justice. Legal Basis: – Cal. Evidence Code § 1200 (hearsay inadmissibility), – *People v. Fuiava* (2012) 53 Cal.4th 622

(admission of repeated, irrelevant misconduct evidence is reversible error).

Cumulative Misconduct Clearly Justified Dismissal

• • Pattern of Collusion:
• Combined judicial, police, and prosecutorial bias, evidenced by intimidation, tampering, and fabrication, destroyed any pretense of fair trial.
• Egregious conduct rises to the constitutional standard where “the only appropriate remedy is dismissal,” as retrial would merely replicate injustice.

Missed Opportunities for Relief:

• At each stage—pretrial (based on evidence fabrication/transcript tampering), during trial (judicial bias, police perjury, prosecutorial hearsay, intimidation), and post-trial (restoration of rights, clerical errors)—counsel declined to move for dismissal.

Grounds for Dismissal (Relief Requested):

• • Cumulative due process violations.
  • Systemic government misconduct and collusion.
  • Prejudice so severe retrial would be unjust and constitutionally insufficient.
  • Legal authorities: US and California Constitution, People v. Batts (2003), Strickland. Washington (4), Caperton v. Massey (2009), Penal Code §§ 96, 96.5, 147, 182.