https://rumble.com/v73v3ye-dinse-stalking-opsaudio-proof-of-illegal-acts-falsified-pc-life-at-risk.html

Entire Audio – Operations with Business to provoke, harass, fabricate LAPD CALLS, LAPD Knowingly writing FORGED and FRUADULANT Police Reports, and Mental Illness Labeling based on what they are telling these extremely large Businesses with Customers and Civilians to do in the Name of MENTAL ILLNESS or HATE to a young child exponentially growing for approximatly 48 years. Everything stated here is HEARSAY, Fabrications, or provaction to instigate reactions.

Admission from Lead Officer Charles Sean Dinse that they are involved in ILLEGAL Procedures Exercising the law in his own way, to HUNT those he FABRICATES Crazy Labels

Charles Sean Dinse with Linton, Norris, Espinoza and Others, Showing Illegal SETUP and FRAME job operations working with BUSINESSES and CIVILIANS in FRAUD and FORGERY to falsify Police Reports to fabricate a pattern of Mental Illness that doesn’t exist.

Seagent Cooper of West Valley – Rewrites IA report to try to make me look crazy as Cover Ups with Paul Humphrey, my friend working for LAPD around 1998 STALKING ME in these group Gas Lighting and Provocation tactics to SETUP, and FRAME or create the illusion of Mental Illness as Operations to remove those they don’t like based on discrimination from society. Wether it be Jewish, fear, insecurity Falsifying Mental Illness Labels.

LAPD wouldn’t even take a Police Report of a girl on video trying to slice me up with a knife, showing they have MOTIVE in Conspiracy to Commit Murder.

Illegal Police Operations with businesses, civilians, and mass groups to try to make people look crazy with civilians, security companies, and private businesses in HATE and DISCRIMINATION operarations.

This involves non stop STALKING, and PROVOCATIONS to instigate reactions to FRAUDULENTL:Y FORGE a paper trial of DEFAMATION OF CHARACTER to create the appearance and of Mental Illness. The Lead Officer Charles Sean Dinse Motive with his FACEBOOK account, and riling the masses FEDERALLY against people he does not like out of HATE. Just as he has broadcast me, Rex Schillenberger who FEDERALLY SUED him for Defamation and Police Misconduct, and many others, using the INTERNET as a weapon to STALK the inferior race, or those who don’t have perfect lives. Conglomerating mass HATE armies against the Target’s and Victims such as myself.

LAPD started on me at a very young age, especially with my friend Paul Humphrey who joined LAPD around 1998 STALKING ME with women and others in these CRY WOLF Defamation Of Character operations building dissinformation across the Internet to the masses to EXECUTE his friend with LAPD and unlimited resources.

In 1991, Kelly Hatch who followed me up to Southern Oregon State College was working on me with Eric Christianson, local police, and Sandiego Police, with the same tactics upon leaving California to go to College.

In my case, all across the United States and World due to the crimes against me esculated since early childhood

Los Angeles Los Department Illegal Profiling Operations – Also Known As Gaslighting Or Gang Stalking

Lead Officer Charles Sean Dinse Serial #34920
Steve Norris Serial #37704
Glenna Espinosa Serial #44710
Dashanay Linton Serial #43696

Detective Shapiro Serial #: 43696

Detective Angela Stewart

Some of the Officers Refusal of Police Reports or Watered Down Police Reports, not on out of countless of reports they are modularizing, instead of putting the pattern of non-stop events together

William D Jones: Serial #40366

David Lin Serial Serial #35371

This situation represents not only a campaign of orchestrated provocation and harassment across countless public businesses, but also an escalating effort—allegedly coordinated by certain law enforcement officers and community members—to systemically profile, label, and remove a targeted individual from society under the pretext of mental instability or dangerousness.

Key Stages of Escalation:

• Repeated Provocation and Gaslighting:

The individual is targeted with chronic, daily provocation—often at the direction or encouragement of authorities—to create a record of disputes, emotional reactions, or escalated confrontations that did not arise naturally, but were instead manufactured by years of subtle and overt harassment.

• Group Victim Claims and Legal Narratives:

Once a negative reaction occurs, staff or affiliated community members are instructed to play the victim, claiming fear, harassment, or disruption—regardless of the reality—thereby generating police reports, warnings, and eventually requests for civil restraining orders.

• Accumulation for Legal Action:

Through the accumulation of these manufactured incidents, authorities and their network amass sufficient paperwork, negative commentary, and hearsay to present the individual as consistently dangerous or unwell—despite the lack of genuine, documented violence or threat.

• Profiling and Mental Health Labeling:

The target is subjected to an unofficial campaign of psychiatric labeling—described as “crazy” or “unstable”—which is not based on any professional mental health assessment, but derives entirely from rumor, prejudice, and an orchestrated paper trail of defamation and hearsay.

• Efforts Toward Incarceration or Permanent Removal:

The ultimate purpose appears to be to escalate civil or criminal penalties—such as seeking not only repeated restraining orders, but eventually legal determinations of dangerousness or mental incapacity, allowing for forced institutionalization or permanent incarceration. Such a result may involve collusion to “paper” the individual into jail, conservatorships, or psychiatric commitment, even in the absence of lawful or factual justification.

Consequences and Risks:

• If successful, this pattern could result in the deprivation of liberty, permanent commitment to mental health facilities, or long-term incarceration—not because of real public safety risk, but as a product of systematic, coordinated profiling, record fabrication, and sustained community-and-police collusion.
• This process not only removes the individual from public life but does so under a stigmatizing and legally questionable banner, often rendering challenges or rehabilitation nearly impossible.
• Such actions are not just violations of civil and constitutional rights, but are among the most severe abuses of law enforcement authority, with lasting and irreparable consequences for the target.

Legal and Civil Rights Analysis:

• Penal Code § 182 (Criminal Conspiracy) applies to any group coordination intended to deprive a person of rights or liberty through illegal means.
• Penal Code § 118.1 (False Official Statement) and Penal Code § 470 (Forgery/Falsification) cover the creation or use of false documentation in support of institutionalization or incarceration.
• California’s Bane Act (Civil Code § 52.1) and 42 U.S.C. § 1983 provide for the protection of due process and civil liberties, which are undermined by these practices.
• PC § 646.9 (Stalking/Harassment) applies where systematic tracking and provocation are present.

Summary:
The described campaign not only seeks temporary exclusion but is directed at building a case for the permanent incarceration or forced removal of the targeted individual from society through coordinated mental health profiling, false documentation, and legal escalation—all in violation of the foundational rights guaranteed by law and the Constitution.

www.KevinPerelmanTarget.com

Police Misconduct Letter To Internal Affairs And Other Agencies

Related to (and associated with) this person’s setup attempts and frame jobs:

• LAPD and Officer Sean Dinse — using “mental illness” tactics to make me look crazy, then pushing for a psych evaluation as an angle to remove me from society and cover up their endless crime spree against me:
  https://wordpress.kevinperelmantarget.com/2017/11/23/officer-sean-dinse-jenson-and-toros/
• Lorena Escobar, Gwen Suazo, Patti Googin, Shanna Briantseva, Fernanda Sime — stalking tactics at Golden State Sports Medical:
  https://wordpress.kevinperelmantarget.com/2017/03/09/lorena-escobar-gwen-suazo-patti-googin-shanna-briantseva-some-of-the-people-that-have-been-hunting-me-in-this-30-year-campaign/
• Police refusing to help me—ever:
  http://www.kevinperelmantarget.com/LawyersRefusingToHelp/Default.aspx
• Archived data of their mass 40-year operations (unorganized and unedited):
  https://cloud.kevinperelmantarget.com/cloudlinks.html
  https://linktr.ee/KevinPerelmanTarget.com
• Aubrey Fisher — sent after me by police, family, friends, and government to end my life:
  https://wordpress.kevinperelmantarget.com/2013/04/22/community-mobbing-aubrey-fisher/

---

Counter-Surveillance with PoliceAbuse.com

One of the first (vague) PoliceAbuse.com reports

I hired PoliceAbuse.com to accompany me on a drive to the San Fernando Valley (CA), Las Vegas (NV), San Diego (CA), Mexico, and Washington, DC. The activities in that trip—in every location—involved the same types of tactics I describe elsewhere. I focus mostly on Washington, DC because I was isolated and didn’t have the energy to write about 99% of what happened day-to-day (for example, every gas station we stopped at). At each stop, people—including employees—acted like they knew me and were working on me with terror tactics, then pretended they didn’t.

Keep in mind: the judicial system will likely use the fact that I contacted PoliceAbuse.com to push psychological labels for their agendas—painting me as a “crazy, violent, paranoid schizophrenic” (the “John Nash” storyline), alongside their 40 years of lies and cover-up operations claiming I’m imagining everything. They’ll ignore that I contacted PoliceAbuse.com for investigation.

Las Vegas was worse, and by the time we reached San Diego, they were mimicking Greg Miller (the private investigator). For example: we sat at a table at McDonald’s, then got up and moved—an employee sat in Miller’s seat and stared at me. Similar things happened in San Diego, and we decided to go to Mexico to prove this was an international operation of worldwide magnitude. In Mexico, at a hotel, we observed angered hotel employees and intimidation attempts whenever I left my room—everything you can imagine.

Miller didn’t want to stay in San Diego long, but San Diego was pivotal because of a girl from Arizona named Christina Stahlinsky (someone I met in IRC who was sent after me), plus Mike Wexler (sent into my life by my brother), and Eric Christianson. All of them pushed road trips, and Christina wanted to meet me in San Diego—linked, in my view, to the San Diego Police Department and frame-job/setup attempts. I can’t tell you the hidden accusations being spread about me, but I can tell you this “San Diego angle” has been worked on me since I met Eric Christianson at Southern Oregon State College—attempting coerced false confessions related to the bullet hole incident in my father’s Mercedes (involving the LAPD), and trying to cover up my brother’s childhood abuse. I didn’t think it was a big deal until I found out my brother was trying to claim I tried to kill or stab him.

There were earlier operations too—like my father taking me on a Caribbean cruise when I was 14 (with Jason Perelman and Darrin Moiselle), forcing alcohol on me (B-52s and Kamikazes), then buying me a Kershaw pocket knife—apparently hoping to flip me into paranoia and make me “go ballistic,” so they could build a narrative. That links to Eric Christiansen taking me to see his girlfriend Jen and her friend Cat—same name as my brother’s girlfriend (Jen Yang). I stopped Eric from bashing Greg Waugh’s head with a crowbar, and later my brother threatened me at 16 that he and his friends would put me in a mental institution (Mike Huntley—introduced by my brother—has spent 25 years on me).

This is what people can’t fathom: what resources does it take to coordinate mass groups to do things like get a teenager drunk on a cruise, seed “Pearl Harbor” hints (because my last name is Perelman), plant a knife narrative, then later claim I’m violent or mentally ill and a danger to myself or others—while pushing worldwide support to erase me, cover it all up, and keep the “I tried to kill my brother” lie alive?

I don’t have as much written down about the other locations, but Washington, DC is the part that exposes security behavior—White House personnel knowing me, tracking me, and trying to intimidate me. If I were just some random person having a “mental breakdown,” why would I be known worldwide? Why would people connected to the White House of the United States behave as if they want me silenced and incarcerated for life?

So we went to Washington, DC (and Mexico, and across the U.S.) with PoliceAbuse.com, specifically to document how far this goes.

Former police sergeant Don Jackson (Diop Kamau) prioritized money over my safety, and refused to provide much of what he promised (video and paperwork), especially after what happened near the White House—where security exposed themselves. Even so, we got enough reactions to show I’m not “imagining” a worldwide incident.

Don Jackson also seemed angry at me. I suspect that ties to defamatory narratives spread about me since childhood, including racist/white-supremacist lies circulated after I kissed a Black girl at Sunny Skies day camp when I was around 8–10—part of a broader libel/slander/defamation campaign. Oddly, he had no problem exposing smaller-scale police corruption on his site, but after the White House he backed off fast.

First PoliceAbuse.com report (vague, despite witnesses—Don Jackson/Diop Kamau, Miller, and another person saw everything; he refused to provide final reports and other promised deliverables, even though it was paid for): [link referenced as “Here” in the original—insert the URL if you have it]

Even incidents like police walking into Starbucks and telling me I’m “not allowed” at any Starbucks in the city (on video, etc.) still showed that something massive is going on.

PoliceAbuse.com could have testified—Don Jackson and Miller—on my behalf in the later 2017 arrests and fabricated charges. But after five months of pretrial, the defense had zero time to prepare: the decision to go to trial came the next day, with no witness prep, discovery work, or evidence prep—making it impossible to contact them and fly them out for testimony. Have you ever heard of a trial where the defense isn’t allowed to prepare?

More related incidents:

• Mike Huntley working with Ron Perelman, Officer Sean Dinse, Detective Angela Stewart—cover-up operations involving Jen Hess:
  https://wordpress.kevinperelmantarget.com/2017/11/23/officer-sean-dinse-jenson-and-toros/

From childhood, police have known what’s been happening and could have stopped it. They didn’t—meaning they’re involved. When I went to them for help, they refused and tried to bully and thug me into silence. Officers calling themselves “Officer Toro” followed me while saying things like, “If you ever take a picture of a person, I will exercise the law in my own way.” The reason is obvious: they don’t want me to have a camera because I can document events. A police force wouldn’t try to cover up a worldwide crime unless they were responsible—and they’re using their resources to try to end my existence.

In my case, this fits the long-running family/police/social worker effort to strip my civil rights and remove me from society through false claims and secret hatred. The more recent arrests tied to the Second Amendment are part of an elaborate operation that links back to my father buying a .357, then the bullet hole in his Mercedes with the LAPD, and a narrative that I tried to kill or scare him with a gun—right after I painted a Grateful Dead watercolor of a cowboy hat, gun, and skull. (Patty Googin, an office employee, told me I “better not show my father,” after I told her I wanted a tattoo of it.)

In college and beyond, people were sent into my life across states trying to extract confessions. The lies spread worldwide kept changing, telling people I was “on the run,” and building global “reporting” systems around me—endless provocations, setup attempts, and frame jobs.

While these nonstop events with the Police, Perelman Family, Psychology Community, and mass community-policing operations all the way down to 5 years old are extremely vast and unheard of — involving elementary school teachers, high school teachers, college professors, and almost every human interaction since 5 years old — to eradicate me at all costs. This is a letter to the Department of Justice and other government oversite agencies exposing these worldwide operations to execute me, and kill 5-year-old children, still going on minute by minute 48 years later.

While they have refused any possible HONEST or FAIR counsel wether Judges, Defense Attornies, or APPELANT Lawyers to represent me. And even Jurors, Private, Public, you name in. All in a major conspiracy. Penal Code 182. Showing that this is not about Law, Order, TRUTH, Due process or anything else other the PURE HATE. The deck is being stacked against a 5 year old JEWISH child with PURE GOVERNMENT, FAMILY, JUDICIAL HATRED, in a conspiracy to commit murder or eradicate at all costs for 50 years with the masses all across the world taking part and no one coming forwards to speak on the side of me, the Victim.

This letter shows a tiny bit of what they have been doing daily in a global extermination or eradication operations. Are they going to look the other way like always for another 50 years while preaching we live in the land of the free, and the United States is the best Government in the world? When it is now the Worst due to lack of checks and balances, and refusal to admit when they are wrong with every horrific crime known to man being exercised by them in the shadows?. and play dumb, and continue to STALK ME, or are they going to be honest, to show ACCOUNTABILITY, for the Perelman Judicial Friends and Police officers of the Perelman Family HUNTING ME out of HATE and agenda, since I was around 5 years old. Is lying over and over since I was 5 years old going to STRENGTHEN our nation for as a good country? Or is it going to expose it for what it really is? I you want to strengthen something. You do what’s right, and learn from your mistakes. Not keep doing them over and over while brainwashing the masses to go on a slaughter, and killing spree in the name of Justice.

Are these mass WORLDWIDE stalking groups going to continue to cover up their Child Raping dirty little secrets they don’t want coming to light with mental rape tactics? Or continue with their Daily STALKING, setup, frame job operations with the black communities, jewish communities, and all other communities helping with such DEATH THREATS as “No Relaxing for you NIGGER” because I kissed a black girl when I was 8 years old at Sunny Skies Day Camp, in which no one would normally care about, or would even have this private information?

What they will do with this information that I’ve presented before, and to the world for a good 10 – 15 years dictates everyone’s freedoms and national security and what our Government really is and stands for, even though they are too arrogant and ignorant to even understand what they are involved in. It will also make a statement as to what the United States Government and your FREEDOMS are really about. Meaning, you have none! And everything they told you about the Constitution of the United States of America is a lie. You are not a free man, and you, your family, and your children are in danger, though you think you may not be — because you are living your life and have done nothing wrong.

You are a FREE man, unil you, Unless we just don’t like or trust you

Any attempt to supress this, and not take action on my behalf proves the TRUTH about what they’ve been doing since I was 5 years old non stop, daily.

This document is a small peice of what’s been going on daily since I was 5 years old as it is extremely complex and vast with a planetary level coordinated privacy violation and psychological warfare campaign to eradicate someone at all costs and dumb it down as teases or a game.

Appears to be deliberate and Intentional Avoidance to allow a complaint, just like 100’s of Police Reports attempts to try to stop the mass Community Policing Charles Sean Dinse, Chief Micharl Moore Crime Spree against me with their Mental Illness and Criminal Label Coverups. And to try to stop any type of Paper Trial of the Truth. Since that day alone 3 locations give me fictitous addresses, not wanting any submission about their criminal Judicial and Police Officer Friends.

Submitted Letters

Department Of Justice

https://rumble.com/v72i292-1142025-bustamante-investigations-with-ariel-footage-exposing-coordinated-s.html

These are supposedly Police, and Community Policing Operations. They are really Child Rape, and JEW kill operaitons. But when LAPD is trying to polish a turd. That’s how they phrase it. That hunting and killing 5 year old jewish children is to create peaceful worlds. What makes it sicker, is it’s started from a Jewish family who cloak themselves in Rabbi’s and religeous groups to try to look good.

Like those child molesting priest rings that were exposed.

But the truth about the porn stars, and strippers with others who were paid to stalk me and hunt are another story. Like Michael Bialys, Victoria Walker, Adriana Olivarez, Aubrey Fisher, and many others. And Roadie Morales with Ron Perelman and Mike Huntley. While in 2001, trying to plant a trash bag of LAPD confiscated Marijuana in my house with LAPD as attempts for drug dealer frame jobs on these daily HATE operations.

Verbal Harassment and Provokings from almost every human contact Worldwide, Groups stalkings with Clothing Colors, Mimic Tactics, Following, Waiting, in mass groups. No matter what city, no matter what age. or Trigger Words or phrases with mass worldwide groups told to do them in repetition, Even while trying to file Police Reports by LAPD in their HATE and RAGE for a 5 year old. And all sorts of varients when you get into the specifics.

Example, Kelly Hatch paid or contacted to follow and Stalk me with the Police from Calabasas High to Southern Oregon State College in 1991. Right as I was leaving California to start a new life, and focus on my future. Showing whatever the Perelman family is mad about in 1977. Is their own personal issues and their own Projection.

This is one of the Car Mental Illness Tactic varients. It esculates around 2011. At Encino Starbucks with LAPD, my family, the Pscyhology Community they are linked to, and pure hatred and rage for their 5 year old who found out in 2001, that there was a Worldwide conspiracy to commit murder, with the Perelman family, Jason Perelman, Jennifer Pilchick Perelman, all my friends growing up, and Jason’s friends with the Judicial System. Clearly paid off or friends of the Paranoid Psychotic Perelman Family. Riling worldwide groups to hunt me for extermination with lame empty statements about behavior which these excuses and justifications to commit cold blooded murder change almost daily for 48 years.

Out of the countless 48 year daily worldwide lies, defamation, dissinformation to the world. LAPD cover up Police Reports, to KILL and get away with it, stating that I’m supposedly, a Public Nuisance. When you can see they are the ones with Jason Perelman, and Jennifer Pilchick Perelman who are the menace to society with their NAZI armies to KILL 5 year old Jewish Children, with the rest of the Perelman Family. With the you had better not tell anyone or we will KILL ERADICATE you with our JUDICIAL FRIENDS.

This is an example of the daily setup and frame job PROVOKINGS, minute by minute to create the appearance of the families original lies, when I was 5 years old. The black communities hate and rage for a Jewish Person who kissed a black girl when he was 8 years old with the same pure hate and rage from the Jewish Community. Showing their bigetod racist hatred, while trying to cover up what they really are and have done for 48 years daily, non stop with their operations to hunt and kill a 5 year old Jewish Child, now 53 and still dealing with their HATRED for anything different then them. The very people who are about law, order, peaceful communities are the same as Adolf Hitler, and the Nazi Party with LAPD and their community Policing Programs with Lead Officer Charles Sean Dinse, and Chief Michael Moore. However.

When they are threatening my life with their barage of DEATH THREATS and ATTACKS. You can see how their “No relaxing for you Nigger” with a large part of the black community Worldwide Applies to their HATRED of an 8 year old Jewish Child Kissing a black girl. However, normally no one could care less about interacial friends or relationships. Yet in my life it’s of the utmost importance. But not for Jason Perelman, he can date whoever he wants. You do the math what it’s really about? Because the Police, Government, and Psychology Community don’t usually launch assasination programs to mentally rape and kill 5 year olds with the masses calimg it’s mental illness as COVER UPS.

I didn’t know my tax paying dollars were paying LAPD to hunt and kill 5 year old Jewish Children from families who are angry that they didn’t want a second child. Blaming the child for their mistakes of not wearing a condom, or using birth control.

Everything is a cover up, of a cover up, daily all the way down to 1977, 5 years old. And their non stop death threats, they are going to hunt me with worldwide groups and the Judicial System to kill me, and I had better not talk or they will hunt me to kill me. And MENTAL ILLNESS labels to cover up their non stop 48 year Conspiracy to Commit Murder.

Normally the people would not stand for this or support it, Normally this wouldn’t be happening, Normally the Police and Psychology Community Wouldn’t be trying to cover this up and kill or eradicate me for finding out what they are doing with my sick family. But whatever they are really trying to cover up, that they will hunt and kill over, is the real question. And what the masses don’t want coming to light while they create newer and newer cover up lies. Exposing an Unheard of amount of GUILT in the masses, and Judicial System.

Just ask Alexis Amore, since she “Spoke with my brother”

Spoke with my STALKING, PSYCHOTIC MURDERING brother

If I’m supposedly a Stalker, According to her, then why hang out and associate with STALKERS and help with worldwide child rapist armies non stop for 48 years since I was 5 years old?

This really does apply to the 48 daily worldwide hypocrites I’ve dealt with Preaching about right and wrong and hunting to kill those they HATE in a mass conspiracy to commit murder to execute a 5 year old.

www.KevinPerelmanTarget.com

www.TheHateCage.com

https://rumble.com/v72kny4-1232025-woodland-hills-increased-rate-of-reds-and-white-grps-3s-at-warner-c.html

https://rumble.com/v72jfhi-1222025-chatsworth-and-zelzah-lawyer-and-stalker-seymour-amster-mail-and-sh.html

https://rumble.com/v72jbhm-1222025-northridge-mall-barclays-coffee-linked-to-golden-state-sports-medic.html

https://rumble.com/v72ja3w-1222025-rite-aid-planet-fitness-plush-billiards-mothers-property-balboa-and.html

https://rumble.com/v72gfm4-11302025-santa-monica-and-marina-del-rey-white-grps-ome-red-grps-parking-lo.html

https://rumble.com/v71xtaa-11182025-encino-area-starbucks-shop-center-w-police-and-community-death-thr.html

https://rumble.com/v71tc56-11162025-calabasas-area-groups-2s-more-backwards-parking-lots-reds-in-2s-is.html

https://rumble.com/v70sp0o-the-woodland-hills-white-car-grouping-tactic-which-instantly-grew-worldwide.html

https://rumble.com/v70to7g-groups-of-jeep-wranglers-at-street-ends-groups-of-whies-at-park.html

https://rumble.com/v70wvt0-10282025-maybe-10-obvious-groupings-mostly-whites-2s-and-2-blues-2s-backwar.html

https://rumble.com/v70ychc-10292025-clears-out-day-private-investigator-makes-commitment-to-come-out-t.html

https://rumble.com/v7103nc-10302025-still-mostly-cleared-out-after-investigator-is-waiting-to-come-out.html

https://rumble.com/v710zmk-10302025-5pm-starting-back-at-park-spread-red-tacti-parking-lot-2s-and-grps.html

https://rumble.com/v718gyk-1142025-coordinated-stalking-and-privacy-violations-when-trying-to-get-help.html

https://rumble.com/v7183s2-1142025-whte-groupings-backwords-lots-less-at-park-but-whites-2s-spread-not.html

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”

www.KevinPerelmanTarget.com

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.