Attorney Sanctioned for Unsupported Claims of Judicial Bias

Wednesday, August 5, 2026

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Court of Appeal:

Attorney Sanctioned for Unsupported Claims of Judicial Bias

Opinion Says Lawyer’s Brief Is Replete With Unsubstantiated Attacks on Retired LASC Judge, Publication Said to Serve as Warning Call to Those ‘Who Appear Before Appellate Bench’

By a MetNews Staff Writer

Div. Four of this district’s Court of Appeal yesterday imposed a $1,000 sanction on a Beverly Hills attorney over the attorney’s “repeated attacks on the integrity” of former Los Angeles Superior Court Judge Stephanie M. Bowick, who retired last year, without any evidentiary support for the claims, saying that “members of the bar may not spew” such allegations “merely because they disagree with a ruling.”

Presiding Justice Helen Zukin authored yesterday’s opinion, joined in by Justices Audra M. Mori and Armen Tamzarian, declaring:

“We publish this opinion as a warning to those who appear before the appellate bench. Challenges to the integrity of the hard-working, dedicated trial judges of this state must be based on evidence in the record, not the personal frustrations of counsel or parties….Counsel must not expect courts of appeal to allow such baseless outbursts.”

The sanctions were imposed on attorney Jeremiah Reynolds of the Beverly Hills office of Eisner LLP for statements he made in an appellate brief challenging Bowick’s rulings against his clients, film producers Sergei Bespalov and Marina Bespalov, who operate the California production and distribution house, Aldamisa International LLC.

He made multiple inflammatory remarks in his opening and reply briefs, including a comment that “the Respondent Court’s two thumbs were firmly on the scale” for the other side and a heading that asserted that “The Respondent Court’s Biased Trial Rulings Violated the Bespalov’s Due Process Rights.”

An accompanying unpublished opinion, also filed yesterday, affirms the judgment entered against Reynolds’ clients following a bench trial over which Bowick presided.

Underlying Dispute

At the heart of the underlying dispute is a distribution deal involving the Russian release of a film entitled, “Sin City II: A Dame to Kill.” The plaintiff, A Company Hungary Kft, agreed to purchase the Eastern European distribution rights to the project, for a total of $4 million to be paid across three installments, from Sartraco Inc. in 2012.

Marina Bespalov signed the agreement on behalf of Aldamisa International, the corporate agent for Sartraco. The Russian theatrical release rights were later transferred to an affiliated entity in 2013, which arranged for another company, Twentieth Century Fox CIS (“Fox Russia”) to collect box-office revenue.

The following year, A Company Hungary, while still owing approximately $1.5 million on the purchase agreement, signed a letter directing Fox Russia to pay all theatrical revenue to Aldamisa Rus LLC, which eventually received $2.03 million in payments. Some of that money, approximately $1.48 million, was purportedly transferred into the Bespalovs’ personal control.

In 2020, A Company Hungary filed a complaint against the Bespalovs for conversion, civil theft, and unjust enrichment, arguing that Aldamisa Rus LLC was entitled to keep the amount reflecting the unpaid balance on the underlying purchase agreement but claiming that the remaining funds should have been returned to the plaintiff.

Bowick found for the plaintiff after a 2023 bench trial, and a judgment was entered awarding A Company Hungary $5.9 million in 2024, reflecting a trebling of $795,708 in compensatory damages plus prejudgment interest.

Appellate Brief

Reynolds opened his appellate brief challenging the judgment by saying:

“This appeal is about double standards. It is also about the egregious misapplication of the receipt of stolen property statute, Penal Code § 496(c), and an ‘[o]rdinary commercial default’ improperly ‘being transformed into a theft’….

“The underlying case is an unremarkable commercial contract dispute regarding the ownership of $795,708 derived from the Russian theatrical distribution of the film Sin City 2. However, due to the Respondent Court’s manifold and prejudicial legal errors and unchecked bias on pivotal evidentiary rulings, this business dispute resulted in a conscience-shocking judgment after bench trial of over $5.9 million against the managers of certain of the relevant commercial entities in their personal capacities.”

After a review of the parties’ filings, which Zukin said revealed 26 “baseless accusations of bias,” Div. Four issued an order to show cause to Reynolds as to why he should not be held in contempt for attacking the integrity of the court.”

Noting that “the Bespalovs twice unsuccessfully sought to disqualify the trial judge in proceedings that terminated with the denial of a writ petition by the California Supreme Court,” the justice said that “Counsel’s response to our order to show cause, both in his written return and his oral presentation, lacked awareness of the nature and severity of his offenses.”

She acknowledged that the attorney apologized for “rhetorical excesses” but remarked that he “undercut” his apology by saying that the statements identified by the court are “neither unsupported by the record nor made in reckless disregard of the truth” and are merely “characterizations and inferences” drawn from the rulings. Zukin wrote:

“This is not sufficient as either defense, explanation, or apology. It implies that counsel inferred bias simply from an adverse ruling, and acted reasonably in doing so. But counsel may not infer bias simply from an adverse ruling….Further, counsel’s statement that his allegations of bias ‘were not presented as independent facts’ rings hollow. Counsel put these allegations into multiple headings of an appellate brief. There is no reason to include such statements in a heading if they are not intended as statements of independent fact.”

Pointing out that “[t]he sole support counsel offered for the accusations…was the fact that the trial court ruled against” his clients, she added:

“Counsel are obviously free to disagree with a ruling, and they are encouraged to explain in an appellate brief, with vim and vigor, why that ruling is wrong….But counsel must not assume an unfavorable ruling means a biased court, much less make that assumption a central part of their appeal.”

Zukin declared: “Contempt of court is a violation under Code of Civil Procedure section 1209, punishable by fine….We find counsel in direct contempt for employing an unsupported heading to assert that ‘The Respondent Court’s Biased Trial Rulings Violated the Bespalov’s Due Process Rights.’ We order him to pay a fine of $1,000 for this offense. We need not further discuss the other 25 offending statements, although they are equally reprehensible.”

Reynolds was also ordered to forward a copy of the opinion to the State Bar.

Contractual Dispute

In the memorandum opinion, also authored by Zukin and joined in by Mori and Tamzarian, the court addressed the Bespalovs’ assertion that the dispute over the Russian payouts were a simple contractual dispute and Bowick erred by finding them liable in tort for damages. Zukin said:

“The Bespalovs assert that because the Letter ‘unconditionally and irrevocably instructs [Fox Russia] to make all Payments to the following bank account…of Aldamisa Rus LLC,” it clearly relinquished A Company Hungary’s right to the money. This argument fails because, as observed by the trial court, the Letter is not a contract signed by the Bespalovs or any of their entities. It is a direction about where distribution revenue is to go, with audit rights given to the original owner of the film, Sartraco—to whom A Company Hungary still owed part of the purchase price for the distribution rights.”

She continued:

“This argument fails because there is no contract between the litigating parties. A Company Hungary has no contractual relationship with Aldamisa Rus, Aldamisa International, or the Bespalovs. Once the money passed into the control of Aldamisa Rus, A Company Hungary had no contractual means to regain control and no contractual remedy when the money was taken.”

The cases is A Company Hungary KFT v. Bespalov, B336640.

Reynolds and his colleague Zachary Elsea acted for himself and the defendants. Alexander D. Pencu and Michael B. Sloan of the New York firm Meister Seelig & Fein, and Mark B. Chassman of the Santa Monica-based Chassman LLP represented the plaintiff.

Bowick had previously been accused of bias in 2023, in the Basset Unified School District v. Superior Court (Ross) case, based on allegations by two attorneys for a losing defendant who said that the jurist changed a ruling favoring their client after she had been seen inviting a colleague, Los Angeles Superior Court Judge Rupert Byrdsong, to her chambers.

According to the lawyers, who filed a statement of disqualification against Bowick, Byrdsong had worked for the firm representing the plaintiffs, Ivie, McNeill, Wyatt, Purcell & Diggs, prior to his appointment to the bench in 2014. The disqualification was denied after Bowick averred that Byrdsong did not enter her chambers.

She said that Byrdsong had mentioned to her ‘[o]n or about June 27, 2022,” that his old firm was trying a case before her and that he had entered her courtroom on July 6 to talk with plaintiff’s counsel.