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:
- An extension of time to file a new or supplemental opening brief.
- Authorization to obtain and include all relevant trial transcripts and supporting documents omitted from the current record.
- 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
Leave a Reply