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:
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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. - 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
