Demand Letter To Robert Shinn & Hannah Shinn

Electronically FILED by Superior Court of California, County of Los Angeles on 12/06/2022 04:23 PM Sherri R.
Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk
1 Ethan J. Brown (SBN 218814)

ethan@bnsklaw.com
2 Sara C. Colón (SBN 281514)
3 sara@bnsklaw.com
Kete P. Barnes (SBN 302037)
4 kete@bnsklaw.com
BROWN NERI SMITH & KHAN LLP
5 11601 Wilshire Blvd., Ste. 2080
6 Los Angeles, CA 90025
T: (310) 593-9890
7 F: (310) 593-9980
8
Attorneys for Defendant,
9 Melanie Lee
10
SUPERIOR COURT OF THE STATE OF CALIFORNIA
11
COUNTY OF LOS ANGELES – STANLEY MOSK COURTHOUSE
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RCP FINANCIAL, INC., a California stock Case No. 22STCV34672
14 corporation; 7M FILMS, INC., a California
stock corporation; SHEKINAH CHURCH, a [Assigned for all purposes to the Hon.
15 California nonprofit corporation; ROBERT Christopher K. Lui, Dept. 76]
16 ISRAEL SHINN, an individual; and
HANNAH GRACE SHINN, an individual; DECLARATION OF SARA C. COLÓN
17 IN SUPPORT OF DEFENDANT
Plaintiffs, MELANIE LEE’S SPECIAL MOTION
18 v. TO STRIKE
19 [Filed concurrently: Defendant Melanie Lee’s
ELISA PRISCYLLA LEIGH, an individual;
20 Notice of Motion and Special Motion to
MELANIE LEE GOLDMAN, an individual;
Strike; Declarations of Melanie Lee, Negar
HALEY MARIE CARROLL, an individual;
21 Saatchi, Alexandra Watkins, Gordon
HALEY ELIZABETH PHIPPS, an
Watkins, Kevin Davis, Aubrey Fisher-
22 individual; KAYLEY IRENE SHAFFER, an
Greene, and Kylie Douglas; Request for
individual; and DOES 1 through 25,
23 Judicial Notice; [Proposed] Order]
inclusive,
24 Date: January 3, 2023
Defendants.
Time: 8:30 a.m.
25 Dept.: 76
26
RES ID: 458204912356
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DECLARATION OF SARA C. COLÓN

1 DECLARATION OF SARA COLÓN
2 I, Sara C. Colón, declare:
3 1. I am an attorney at law licensed to practice in all courts in the State of
4 California, am a partner at the law firm of Brown Neri Smith & Khan, LLP, and am counsel
5 for Defendant Melanie Miriam Lee (named in the complaint as Melanie Lee Goldman). I
6 make this declaration in support of Defendant Lee’s Special Motion to Strike Pursuant to
7 Code of Civil Procedure § 425.16. I have personal knowledge of the facts set forth below,
8 and if called to testify, I could and would competently testify to them.
9 2. On October 12, 2022, my office sent a demand letter to Plaintiff Robert Shinn
10 on behalf of Elisha Leigh, Defendant Melanie Lee’s sister. The letter set forth a number of
11 allegations against Robert and threatened to sue him for several causes of action including
12 labor code violations, sexual harassment, and intentional infliction of emotional distress. The
13 letter requested a response by October 21, 2022. A true and correct copy of the demand letter
14 is attached hereto as Exhibit A.
15 3. On October 18, 2022 my office sent a demand letter to Plaintiff Hannah Shinn
16 on behalf of Elisha Leigh. The letter set forth a number of allegations and claims against Ms.
17 Shinn and requested a response by October 28, 2022. A true and correct copy of the demand
18 letter is attached hereto as Exhibit B.
19 4. On October 20, 2022, counsel for Robert Shinn and Hannah Shinn wrote my colleague
20 Ethan Brown and stated, “Needless to say, the Demand Letters contains [sic] a voluminous
21 amount of information and allegations. Given that we have just received the letters and are
22 still in the process of being retained, we simply will not be in a position to respond
23 substantively by tomorrow. That said, I expect to be up to speed quickly and to send you a
24 formal response next week.” (Emphasis added). A true and correct copy of that
25 correspondence is attached hereto as Exhibit C.
26 5. The following week, on October 28, 2022, Plaintiffs filed the instant lawsuit
27 against Defendants Melanie Lee and her sister Elisha Leigh.
28 6. Robert and Hannah Shinn never otherwise responded to the demand letters.
DECLARATION OF SARA C. COLÓN 1
1
2 I declare under penalty of perjury under the laws of the State of California that the
3 foregoing is true and correct. Executed on December 6, 2022 at Los Angeles, California.
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Sara C. Colón
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OMNIBUS REQUEST FOR JUDICIAL NOTICE

2
EXHIBIT A
October 12, 2022
Via Email and U.S. Mail
Robert Israel Shinn

royalyork78@yahoo.com
gigafir-glory@yahoo.com
4435 Camellia Ave.

Studio City, CA 91602
191 E. City Place Dr.

Santa Ana, California 92705
7754 McGroarty St.

Tujunga, CA 91042
7744 McGroarty St.

Tujunga, CA 91042
7742 McGroarty St.

Tujunga, CA 91042
RE: Elisha Priscylla Leigh Demand Letter
Dear Mr. Shinn:
Our firm represents Elisha Leigh (“Ms. Leigh”). Ms. Leigh has retained our firm to file a
lawsuit against you for general, special, and punitive damages arising out of your actions in
connection with Shekinah Church and RCP Financial, Inc. At trial, you, Hannah Shinn, Matthew
Shinn, Isaiah Shinn, Shirley Kim, Young Bin Kim, Christina Keller, Abraham Park, Jenny Park,
Khloe Shinn, Daniel Joseph, Eung Seok Son (aka: Luke), Shekinah Church, Alpha Plus Realty
(“Alpha”), and RCP Financial, Inc. (“RCP”), Imaginating Pictures (collectively the “Shekinah
Parties”) will be liable to Ms. Leigh for millions of dollars in light of the actual and punitive
damages as well as attorneys’ fees available on Ms. Leigh’s claims. A Los Angeles jury would
readily award Ms. Leigh generous damages because of your unconscionable treatment of her, as
set forth more fully below. Ms. Leigh hereby demands $25 million to settle her claims before
filing a lawsuit.
It is hard to summarize the nearly twenty-three years of brainwashing, physical, sexual and
emotional abuse, manipulation, and exploitation to which you subjected Ms. Leigh. You referred
to yourself as “the Man of God” and preached to your church members that without you, they
would be cursed. You convinced Ms. Leigh and other church members that unless they fully
BROWN, NERI, SMITH & KHAN LLP
October 12, 2022
Page 2
submitted to you, their lives and the lives of their families would be destroyed, and that they would
go to hell. You specifically told them that if they did not submit to you, they would experience
poverty, sickness, and the death of their loved ones. You required church members to tell you
their deepest fears and secrets, and then manipulated them by saying that those fears would come
to pass if they did not submit to you. To you, full submission meant economic and physical
submission, which is how you justified the financial and sexual abuse set forth herein.
At your hands, Ms. Leigh lost priceless years of her life and at least millions of dollars.
The Shekinah Parties conspired to and did violate numerous financial and labor laws. Many of
the Shekinah Parties, including you, subjected Ms. Leigh to emotional abuse and humiliation. You
also routinely sexually assaulted and harassed Ms. Leigh while simultaneously siphoning her
income for your personal use and business ventures. Ms. Leigh has suffered extreme distress
because of the Shekinah Parties’ actions, and she intends to do whatever it takes to obtain redress
for what you have taken and done.
Please direct all future communications about this matter to the undersigned. Do not
contact our client directly.
Financial Control
For decades, you completely controlled Ms. Leigh’s finances with the assistance of your
wife, Hannah Shinn. As a young woman from Korea in her late teens, vulnerable and abandoned
by her parents, Ms. Leigh was the perfect target for your growing church. You recruited her as a
member in 1999. Ms. Leigh stayed with the church in substantial part because she became
financially reliant on you. When Ms. Leigh first joined the church, she did not have a driver’s
license or a green card. When her driver’s license came in the mail, you kept it until she agreed to
join the church. You convinced her that the only reason she was able to obtain a license as an
undocumented person was because you had prayed for it and that, therefore, she owed you her life.
While she was undocumented, you had her work for two companies but instructed those companies
to make payments to a different church member. Ms. Leigh didn’t receive any of the funds sent
to that church member and instead received a small, weekly allowance in cash. And she had to
account for every purchase she made with that allowance, even chewing gum. Ms. Leigh was
young and did not have legal status to work here. After being indoctrinated and manipulated by
you, she felt afraid that she would be unable to make a living for herself any other way.
Ultimately, Ms. Leigh became a licensed real estate broker. For thirteen years, while she
made the Shekinah Parties millions of dollars as a real estate broker, you did not compensate Ms.
Leigh for her work. At first, she simply was not paid and instead was given a small cash allowance.
Later you paid her in part but into an account controlled by church members, such as Hannah Shinn
and Shirley Kim. The Shekinah Parties manipulated Ms. Leigh into believing that great harm
would come to her if she did not return almost all of her income to you and the church. You didn’t
depend upon manipulation alone –to ensure that Ms. Leigh provided the Shekinah Parties with her
October 12, 2022
Page 3
income, and presumably to avoid certain of the Shekinah Parties’ tax obligations, one of your
church members was always listed on her account. This gave the Shekinah Parties the ability to
control deposits and withdrawals from her account. Furthermore, you and your associates required
Ms. Leigh to take the extraordinary step of pre-signing checks that you would ultimately write to
the Shekinah Parties and their affiliates, including for the personal expenses of other persons.
None of this was properly reported to the tax authorities in tax returns prepared for Ms. Leigh by
the Shekinah Parties. A substantial portion of these funds was used to pay expenses Ms. Leigh
had nothing to do with and fund your companies, including by payments to Abraham Park, Kloe
Shinn, Daniel Joseph, Christina Keller, Lemuel Betton, Hannah Shinn, and other church members.
That is embezzlement.
In 2021, the Shekinah Parties, at your direction and with the help of Hannah Shinn,
Christina Keller, and Jenny Park, also took approximately $100,000 in COVID relief funds that
should have been paid to church members and instead prepaid many of Alpha’s expenses. You
also took some of these funds as cash and used them to pay personal expenses like your utility
bills. Not only did you fail to give any of these funds to Ms. Leigh, but you also stopped paying
her salary entirely for six months and took $800 per month in unemployment payments directed
to her for your own benefit.
The Shekinah Parties’ embezzlement of Ms. Leigh’s funds totals approximately $500,000.
This unprecedented control by an employer of its employee’s finances was not only immoral, but
it was also illegal.
Emotional Abuse
As if the financial control of Ms. Leigh was not enough, you also subjected her to emotional
abuse. Ms. Leigh managed to extricate herself from the church in 2004 and got married in March
2008. At that point, Ms. Leigh’s sisters were still involved in the church, and you used them to
reel her back in. Even when Ms. Leigh had left the church, you continued to monitor her through
her sisters. You told her sisters to remind Ms. Leigh that because she left the church she was out
of God’s grace and was going to hell or would die. This messaging caused Ms. Leigh severe
depression. After years of this manipulation while Ms. Leigh was not involved in the church, Ms.
Leigh’s sister (at your behest) called her in November 2008 and asked Ms. Leigh to meet with you.
When you met, you presented yourself to Ms. Leigh as a savior. You pressured her to file for
bankruptcy, divorce her husband at the time, and give her dogs away – presumably to make her
totally and utterly dependent on you. You took advantage of the fact Ms. Leigh was behind on her
bills and falsely promised her financial stability and salvation in exchange for her dedicating her
life to you, once again. Ms. Leigh worked for you as a real estate broker and was the broker of
record for Alpha and RCP. At that point, Ms. Leigh felt pressured to make money for you. You
claimed you had no money at the time but assured her that everything would be taken care of as
long as she worked. Ms. Leigh felt a sense of obligation to you.
October 12, 2022
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You would force Ms. Leigh to take part in actions to humiliate herself and punish her for
breaking your “rules.” She was repeatedly berated in front of other church members. You verbally
abused her and would often require hours of manual labor from her, for which you purposely
credited other individuals. In addition to the money you embezzled from her, you and members
of the church, forced her to surrender personal belongings worth approximately $500,000 as
punishment for trying to separate herself from your stronghold. First, in 2009, you showed up
unannounced with other church members including Daniel Joseph and Shirley Kim, to her
residence at 511 Green Acre Drive and packed her belongings and took them from her possession,
informing her that this was an instruction and disobedience would not be allowed. Designer bags,
designer clothes and shoes, jewelry, furniture, perfume, make up, kitchen appliances, and cash
were among the many items you confiscated at that time. Then in 2010, you and Hannah took all
of her belongings from her while she was living with other church members at Madison Circle in
Anaheim. You left with a car full of Ms. Leigh’s belongings. While you fed Ms. Leigh false
promises of hope, gifts, and heaven, you instead caused her to lose more than she could have ever
imagined.
Sexual Harassment and Assault
As with most of the dozens of women you lured into the church, you regularly sexually
harassed and assaulted Ms. Leigh. In addition to the financial and emotional manipulation, you
controlled her ability to engage in relationships with others. Having set up separate living quarters
for men and women, you required that the church approve any relationships Ms. Leigh was to have
with a man.
Knowing that her marriage was struggling, you started making unwelcomed sexual
advances to Ms. Leigh around 2009, even though you were married to someone else. You started
grooming her to have sex with you by coming to her home when she was alone and asking her to
massage your thighs. This continued for about one year and each time you ordered a massage you
instructed her to get closer and closer to your crotch. One day you went to the offices of what was
then Giga Financial, another of your companies. You ordered Ms. Leigh to go to the conference
room and remove her clothing so that you could see whether she had been losing weight. You
started touching her, put her hand on your crotch, first made her perform oral sex on you and then
made her have intercourse with you.
Between 2010 and 2011 Ms. Leigh was living in Tustin with other church members in a
home you owned. Multiple times a week you met Ms. Leigh there and ordered her to take a shower
with you, wash your body, and have oral and penetrative intercourse with you. Afterwards, she
had to return to work. You also subjected other women that lived there to the same routine, but at
different times of the week.
When you lived in Laguna Beach from 2011 to 2012, you coordinated the schedule of your
wife and children so that the house would be empty once a week. When the house was empty, you
October 12, 2022
Page 5
ordered her to visit you and shower with you, wash your body, have oral and penetrative
intercourse with you, and return to work, just as the case had been in Tustin.
The office for Alpha and RCP, located at 191 E. City Place in Santa Ana, had a bedroom
on the third floor, and you would come to the office during the workday and force Ms. Leigh to
engage in sexual acts with you as a condition of maintaining her employment. These sexual
advances so disturbed Ms. Leigh that she again left the church in 2012.
You coerced Ms. Leigh to have sex with you at a time in her life when you exerted so much
control over her that she truly had no free will. She left with nothing and became very sick,
experiencing anxiety attacks and depression so severe that she could not leave her house. You led
Ms. Leigh to believe she was being punished and going to hell. You told her you could only help
her if she returned to the church. So, she did.
After Ms. Leigh rejoined in 2014, you had Shirley Kim move into Ms. Leigh’s home in
Irvine and monitor her every move. You and Shirley had sex on Ms. Leigh’s bed while she was
at work. You took her BMW and gave her a Hyundai. Shirley added herself to Ms. Leigh’s bank
account, gave her no allowance, and demanded that Ms. Leigh ask permission for everything she
wanted to buy, including the food Ms. Leigh ate. Shirley often refused permission when Ms. Leigh
did ask. Shirley also took all of Ms. Leigh’s belongings including, makeup, clothes, furniture, and
kitchenware, and distributed them to other church members. Shirley replaced the items she took
from Ms. Leigh with used shoes and clothing from the other church members along with their
leftover makeup.
When Ms. Leigh returned to the church, she was told she had to marry Luke Son, who was
the janitor of Shekinah. Ms. Leigh refused because she was disgusted by him and found him
creepy. Regardless, for weeks in 2016, Ms. Leigh was ordered by Shirley Kim, at your direction,
to have intercourse with Luke. Ms. Leigh refused. Desperate to avoid having sex with Luke, she
told you and Shirley that she had a rash on her vagina.
Shortly thereafter, you went to see Ms. Leigh while she was working at City Place, where
Shirley was living on the 3rd floor. You took Ms. Leigh to Shirley’s bedroom, ordered her to
spread her legs, and saw that she didn't have a rash. Shirley was there while you inspected Ms.
Leigh. Shirley then ordered Ms. Leigh to go have sex with Luke at another church member’s home
in Orange and texted Ms. Leigh throughout to make sure it was happening. Ms. Leigh had never
felt so humiliated in her life. Shirley made Ms. Leigh believe that she had to do this in order to
get rid of depression and anxiety that she was suffering. Ms. Leigh later found out that you offered
Luke sex with Ms. Leigh in exchange for access to Luke’s family’s connections to a prominent
Korean entertainment company.
Your unwelcomed sexual advances on Ms. Leigh resumed in May 2020 at the home in
Tujunga where she was living and working. On that day you showed up unannounced, laid naked
October 12, 2022
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on her bed, and ordered her to have sex with you. This continued at least once a week until she
left Shekinah Church in May 2022.
Shinn Family, Shirley Kim, Christina Keller, Abraham Park, and Daniel Joseph
Through your direction, your wife, Hannah Shinn, controlled all the finances for Alpha,
RCP, and the church members’ banking accounts, including Ms. Leigh’s. She was responsible for
coordinating the logistics of the Shekinah Parties’ tax evasion and embezzlement. Your son, Isaiah
Shinn, assisted you in recruiting members to the church and knowingly received embezzled funds
from church members. Your daughter, Kloe Shinn, knew of your sexual abuse and harassment of
church members, and she also knowingly received embezzled funds. Shirley Kim is an attorney
who handles your production business, is a broker for Alpha, and most recently had some members
of your church sign an unconscionable NDA. Abraham Park and Shirley Kim are the legal owners
of 191 City Place Drive, where all the Shekinah businesses are registered. You also knowingly
received embezzled funds from church members. Until he left in May of 2022, Daniel Joseph was
your right-hand man and assisted you in all of your wrongdoings. These parties are directly liable
for many of the claims set forth below and for conspiracy to commit and aiding and abetting you
in committing the claims set forth below.
As you are aware, given your role in orchestrating them, there are many more wrongs the
Shekinah Parties committed against Ms. Leigh and other members of the church, which we have
not detailed here, but that would certainly be included in a lawsuit should you force Ms. Leigh to
file one.
I. LIABILITY
Below is a sampling of the causes of action Ms. Leigh will bring against the Shekinah
Parties.
A. FRAUD: INTENTIONAL MISREPRESENTATION, DECEIT, AND

CONCEALMENT
In California, fraud embraces anything intended to deceive, including all statements, acts,
concealments, and omissions involving the breach of a legal or equitable duty, trust, or confidence
that results in injury to one who justifiably relies thereon. Ach v. Finkelstein (1968) 264
Cal.App.2d 667. “One who willfully deceives another with intent to induce [them] to alter [their]
position to [their] injury or risk, is liable for any damage which [they] thereby suffer[].” Cal. Civ.
Code § 1709. Deceit is either: “(1) [t]he suggestion, as a fact, of that which is not true, by one
who does not believe it to be true; (2) [t]he assertion, as a fact, of that which is not true, by one
who has no reasonable ground for believing it to be true; (3) [t]he suppression of a fact, by one
who is bound to disclose it, or who gives information of other facts which are likely to mislead for
October 12, 2022
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want of communication of that fact; or (4) [a] promise, made without any intention of performing
it.” Cal. Civ. Code § 1710.
You represented that the funds you took from Ms. Leigh were for the church, which was
not, in fact, permitted as a church. Eventhen, the funds were not even used for Shekinah. Instead,
the funds were used to benefit you and members of your family personally. You made these
representations of material fact that were false and misleading and which Ms. Leigh relied upon
to her detriment. The truth was that you preyed on younger individuals, such as Ms. Leigh,
exposing them to a fraudulent scheme organized to manipulate them and take advantage of their
faith. You hid from Ms. Leigh that you simply intended to profit from her labor and her body, as
you have done with so many other young people. You concealed and suppressed these facts with
no intention of informing Ms. Leigh or others of your scheme. As a proximate consequence of
your wrongful acts against Ms. Leigh, she has suffered emotional distress and other general and
special damages.
B. INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
You are also liable to Ms. Leigh for intentional infliction of emotional distress. A cause
of action for intentional infliction of emotional distress exists when there is (1) extreme and
outrageous conduct by the defendant with the intention of causing, or reckless disregard of the
probability of causing, emotional distress; (2) the plaintiff’s suffering severe or extreme emotional
distress; and (3) actual and proximate causation of the emotional distress by the defendant’s
outrageous conduct. “A defendant’s conduct is ‘outrageous’ when it is so ‘extreme as to exceed
all bounds of that usually tolerated in a civilized community.’” CACI No. 1600; Hughes v. Pair
(2009) 46 Cal.4th 1035, 1050-1051.
For decades, you controlled every aspect of Ms. Leigh’s life, leading her toward exceeding
vulnerability and loss of self-identity. On multiple occasions, you engaged in acts of sexual assault
and coercion against Ms. Leigh. Regularly, you forced her to do things to humiliate herself and
punished her for breaking your rules or not following your instructions. You humiliated her in
front of other members of Shekinah. You fully intended to cause Ms. Leigh severe emotional
distress to manipulate her into fulfilling your wishes. You consistently threatened her with hell if
she disobeyed your commands, knowing that such fears would paralyze her and force her to obey.
As a direct result of your wrongful conduct, Ms. Leigh sustained severe emotional distress and
pain, emotional anguish, fear, anxiety, humiliation, embarrassment, and other physical and
emotional injuries and damages that are substantial and continuing.
C. LABOR VIOLATIONS
The Shekinah Parties are also liable to Ms. Leigh for multiple labor violations. It is
unlawful for any employer to collect or receive from an employee any part of wages theretofore
paid by said employer to said employee. Cal. Lab. Code § 221. In actions for such a violation,
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reasonable attorney’s fees and costs are often awarded to the prevailing party. Cal. Lab. Code §
218.5. Moreover, whoever knowingly provides or obtains the services of a person by threats of
serious harm or by means of any scheme, plan, or pattern intended to cause the person to believe
that, if that person did not perform such labor or services, that person would suffer serious harm
shall face fines or imprisonment. 18 U.S.C. § 1589(a)–(d). Serious harm means “any harm,
whether physical or nonphysical, including psychological, financial, or reputational harm, that is
sufficiently serious, under all the surrounding circumstances, to compel a reasonable person of the
same background and in the same circumstances to perform or to continue performing labor or
services in order to avoid incurring that harm.” 18 U.S.C. § 1589(c)(2).
As part of your scheme, Ms. Leigh essentially performed uncompensated labor, working
many hours for little or no compensation for your benefit. She was pressured into performing
labor and personal services for you and other Shekinah Church members, where the value of her
labor was devalued, regardless of her skills. In exchange for her work, she was credited a small
rate or a nominal amount of money. When she was compensated for her work, you and other
members would withdraw large sums of money from her accounts that you and other members
controlled. You consistently threatened Ms. Leigh with hell, humiliation, or other punishment if
As a result, Ms. Leigh was consistently and reasonably in fear of serious harm if she did not follow
your instructions.
D. BREACH OF FIDUCIARY DUTY
The Shekinah Parties, including but not limited to you, Hannah Shinn, and Shirley Kim,
are also liable to Ms. Leigh for breach of fiduciary duty. A fiduciary relationship is created where
a person reposes trust and confidence in another, and the person in whom such confidence is
reposed obtains control over the other person's affairs. Richard B. LeVine, Inc. v. Higashi (2005)
131 Cal. App. 4th 566. A fiduciary relationship is a recognized legal relationship, and a fiduciary
must give priority to the best interest of the beneficiary; in addition to this duty of preference
toward the beneficiary, the fiduciary also is required to manage the subject matter of the
relationship with due care, must account to the beneficiary, and must keep the beneficiary fully
informed as to all matters pertinent to the beneficiary's interest. Oakland Raiders v. National
Football League (2005) 131 Cal. App. 4th 621. Similarly, a "confidential relationship" may be
founded on a moral, social, domestic, or merely personal relationship as well as on a legal
relationship. Persson v. Smart Inventions, Inc. (2005) 125 Cal.App.4th 1141. Punitive damages
may be awarded where a defendant is guilty of oppression, fraud, or malice, proven by clear and
convincing evidence. Cal. Civ. Code § 3294; see Michelson v. Hamada (1994) 29 Cal.App.4th
1566, 1582 (punitive damages appropriate for breach of fiduciary duty constituting constructive
fraud); see also Hobbs v. Bateman Eichler, Hill Richards, Inc. (1985) 164 Cal.App.3d 174, 194
(Cal. Civ. Code § 3294 applies to actions for breach of fiduciary duty).
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You, Hannah Shinn, and Shirley Kim had a fiduciary duty to Ms. Leigh based on your
control of her finances, and you breached that duty. Ms. Leigh’s financials were within the
Shekinah Parties’ control, and you failed to prioritize or even consider her best interests or manage
her financials with due care. Instead, you fraudulently and maliciously used her accounts as
another tool to control and manipulate Ms. Leigh. Instead of compensating Ms. Leigh for her
work, you coerced Ms. Leigh into pre-signing checks that you would ultimately write to the
Shekinah Parties and their affiliates, including for the personal expenses of other persons. For
example, on multiple occasions, Ms. Leigh’s bank accounts were used to pay for the rent of Shirley
Kim, Daniel Joseph, and Kloe Shinn. Additionally, Ms. Leigh’s accounts were used to make
monthly payments for Hannah Shinn’s BMW, credit card payments for Shekinah church members,
and maintenance and utility payments for the Shekinah Parties and their affiliates. You left Ms.
Leigh with a pitiful monthly allowance and did not even come close to complying with your
fiduciary duty to her.
E. SEXUAL HARASSMENT
In addition, you are also liable to Ms. Leigh for sexual harassment, which, under both Title
VII of the Civil Rights Act of 1964 and the Fair Employment and Housing Act (FEHA), is
considered a form of discrimination in employment. Under FEHA, “harassment” is defined as
“conduct outside the scope of necessary job performance, conduct presumably engaged in for
personal gratification, because of meanness or bigotry, or for other personal motives.” Reno v.
Baird (1998) 18 Cal.4th 640, 645. It is enough that the individual making the
unwelcome sexual advance was plaintiff's supervisor and that a link to employment benefits could
be inferred under the circumstances. Holly D. v. California Institute of Technology (9th Cir. 2003)
339 F.3d 1158, 1173. “Such a claim may lie either when continued employment has been
expressly conditioned on participation in sexual acts or when the supervisor's words or conduct
would communicate to a reasonable woman in the employee's position that such participation is a
condition of employment.” Id. (emphasis added). Further, if a party submitted to the advances
only out of fear of losing a job benefit, she can still state a claim for harassment. Meritor Sav.
Bank, FSB v. Vinson (1986) 477 U.S. 57, 68.
You were Ms. Leigh’s employer and supervisor at Giga, Alpha, and RCP. On multiple
occasions, you coerced Ms. Leigh to have sex with you at a time in her life when you exerted so
much control over her that she truly had no free will. You set up the business with a bedroom on
the third floor, and you would come to her business during the workday and force Ms. Leigh to
engage in sexual acts with you. You also forced Ms. Leigh to have sex with you at her home and
at your home while she was employed by you and your companies. The implication was that if
she did not have sex with you, she would lose her job and go to hell. After years of controlling
Ms. Leigh’s every action, she reasonably felt there was no option but to submit to your requests or
face being punished for disobedience.
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F. GENDER VIOLENCE
Additionally, your sexual relationship with Ms. Leigh was not consensual and therefore
constituted sexual assault. “Any person who has been subjected to gender violence may bring a
civil action for damages against any responsible party. The plaintiff may seek actual damages,
compensatory damages, punitive damages, injunctive relief, any combination of those, or any other
appropriate relief. A prevailing plaintiff may also be awarded attorney's fees and costs.” Cal. Civ.
Code, § 52.4(a). Gender violence is a form of sex discrimination and includes the use, attempted
use, or threatened use of physical force against the person or property of another, committed at
least in part based on the gender of the victim. Cal. Civ. Code § 52.4(c).
You controlled Ms. Leigh’s living arrangements, checking accounts, food intake, and every
aspect of her life, including her ability to enter into relationships. Having set up separate living
quarters for church members, you required that any relationships Ms. Leigh was to have with a
man be approved by the church. Because of your actions, set forth more fully above, Ms. Leigh
sustained severe emotional distress and physical pain, emotional anguish, fear, anxiety,
humiliation, embarrassment, and other physical and emotional injuries, as well as economic and
non-economic damages.
G. RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS ACT

(RICO)
In addition to fraud, the Shekinah Parties are liable to Ms. Leigh pursuant to RICO.
RICO makes it unlawful for any person to do the following acts with respect to an enterprise
engaged in, or affecting, interstate or foreign commerce: (a) to acquire an interest in, or the
establishment or operation of, the enterprise through the use of income derived from a pattern of
racketeering activity or collection of an unlawful debt; (b) to acquire or maintain an interest in, or
control of, the enterprise through a pattern of racketeering activity or collection of an unlawful
debt; (c) to conduct or participate in the conduct of the enterprise's affairs through a pattern of
racketeering activity or collection of an unlawful debt, where the person is employed by, or
associated with, the enterprise; (d) to conspire to do any of the aforementioned acts. 18 U.S.C., §
1962.
You conspired with members of your companies and church to operate and did, in fact,
operate a racketeering enterprise. Through this enterprise, you physically and psychologically
abused people and engaged in, among other wrongful acts, embezzlement, tax fraud, sexual abuse,
sexual harassment, forced labor, mail fraud, and wire fraud, bilking Ms. Leigh and others out of
large sums of money. Over time, you established multiple businesses, entities and groups through
which your enterprise could affect its scheme, achieve its objectives, bilk numerous Shekinah
Church members out of their hard earned money, establish and profit from businesses supported
by labor that was not paid in compliance with California laws, fraudulently obtain donations to a
fake “church”, avoid paying taxes, and engage in a myriad of other predicate racketeering acts.
October 12, 2022
Page 11
You knowingly managed and operated this enterprise, destroying numerous lives, including Ms.
Leigh’s, while enriching and aggrandizing yourself, maintaining a highly abusive environment
that enabled you to manipulate and coerce members into doing as you commanded for both
financial and psychological gain.
II. SETTLEMENT DEMAND
After years of hard work at your companies Ms. Leigh had not choice but to leave Shekinah
with almost nothing. This letter shall serve as a formal demand that you provide Ms. Leigh
$25,000,000. This represents a substantial discount on the amount that a jury would award Ms.
Leigh for emotional distress and punitive damages. In light of the circumstances surrounding this
case, your clear-cut liability, and your actions, which led to Ms. Leigh’s substantial damages, we
presume that you will not want to engage in protracted litigation.
Ms. Leigh would prefer to move on with her life, but if we do not hear back from you by
5:00 PM on October 21, 2022, Ms. Leigh will file a civil complaint against the Shekinah Parties.
This is a confidential settlement demand as contemplated under California Evidence Code

§ 1152 and is inadmissible for any purpose in litigation. This demand letter is written without
prejudice to the rights and claims of our client, all of which are expressly reserved.
Sincerely,
Ethan J. Brown
of BROWN, NERI, SMITH & KHAN LLP
EXHIBIT B
October 18, 2022
Hannah Shinn
hannahgrace788@gmail.com
hannah@shekinahchurch.com
hannah@shinnreg.com
4435 Camellia Ave.

191 E City Place Dr

Santa Ana, CA 92705
Dear Ms. Shinn:
connection with Shekinah Church and RCP Financial, Inc. At trial, you, Robert Shinn, Matthew
Kloe Shinn, Daniel Joseph, Eung Seok Son (aka: Luke), Shekinah Church, Alpha Plus Realty
(“Alpha”), RCP Financial, Inc. (“RCP”), and Imaginating Pictures (collectively the “Shekinah
set forth more fully below and in the letter we sent to Robert Shinn, attached hereto. Ms. Leigh
hereby demands $5,000,000 to settle her claims before filing a lawsuit.
I. LIABILITY
The attached letter to Robert Shinn (“Letter”) provides a sampling of the causes of action
Ms. Leigh will bring against the Shekinah Parties. In addition to direct liability for fraud,
intentional infliction of emotional distress, and violation of labor laws, you are liable for all claims
described in the Letter on grounds of civil conspiracy and aiding and abetting in relation to fraud,
intentional infliction of emotional distress, numerous labor law violations, breach of fiduciary
October 18, 2022
Page 2
duty, sexual harassment, gender violence, and Racketeer Influenced and Corrupt Organizations
Act (RICO).
A. CIVIL CONSPIRACY
Civil conspiracy is “a legal doctrine that imposes liability on persons who, although not
actually committing a tort themselves, share with the immediate tortfeasors a common plan
or design in its perpetration.” City of Industry v. City of Fillmore (2011) 198 Cal.App.4th 19, 211-
12. In California, the elements of a civil conspiracy are “(1) the formation of a group of two or
more persons who agreed to a common plan or design to commit a tortious act; (2) a wrongful act
committed pursuant to the agreement; and (3) resulting damages.” Id. By participation in a civil
conspiracy, a coconspirator effectively adopts as his or her own the torts of other coconspirators
within the ambit of the conspiracy. Applied Equipment Corp. v. Litton Saudi Arabia Ltd. (1994)
7 Cal.4th 503, 510-11. In this way, “a coconspirator incurs tort liability co-equal with the
immediate tortfeasors.” Id. “A conspiracy may be a continuing one; actors may drop out, and
others drop in; the details of operation may change from time to time; the members need not know
each other or the part played by others; a member need not know all the details of the plan or the
operations; he must, however, know the purpose of the conspiracy and agree to become a party to
a plan to effectuate that purpose.” Craig v. U.S. (9th Cir. 1936) 81 F.2d 816, 822.
For decades, you conspired with your husband, Robert Shinn, and the Shekinah Parties to
keep Ms. Leigh in the church so that you and the Shekinah Parties could (1) embezzle Ms. Leigh’s
earnings instead of compensating her, (2) evade taxes, and (3) coerce Ms. Leigh into having sex
with various members of the Shekinah Parties in order to reward those parties for various benefits
they conferred on the Shekinah Parties. Through Robert’s direction, you controlled all the finances
for Alpha, RCP, and the church members’ banking accounts, including Ms. Leigh’s. You were
responsible for coordinating the logistics of the Shekinah Parties’ tax evasion and embezzlement.
B. AIDING AND ABETTING
Those who “aid and abet” a tort are also liable as joint tortfeasors. “Liability may be
imposed on one who aids and abets the commission of an intentional tort if the person (a) knows
the other's conduct constitutes a breach of duty and gives substantial assistance or encouragement
to the other to so act or (b) gives substantial assistance to the other in accomplishing a tortious
result and the person's own conduct, separately considered, constitutes a breach of duty to the third
person. American Master Lease LLC v. Idanta Partners, Ltd. (2014) 225 Cal.App.4th 1451, 1474
(internal citation omitted).
You knowingly and willingly assisted Robert Shinn and the Shekinah Parties in embezzling
Ms. Leigh’s funds and in sexually harassing her. You knew that Ms. Leigh’s fears of hell,
humiliation, or other punishment by the Shekinah Parties would paralyze her and force her to obey.
A few examples of your involvement include but are not limited to:
October 18, 2022
Page 3
• In 2010, you assisted in taking all of her belongings from her while she was living with
other church members at Madison Circle in Anaheim. You left with a car full of Ms.
Leigh’s belongings.
• In 2021, the Shekinah Parties, with your help took approximately $100,000 in COVID
relief funds that should have been paid to church members and were instead used to prepay
many of your companies’ and personal expenses.
• Around 2017, you instructed Ms. Leigh to pre-sign blank checks, and from her checking
account, you paid your monthly payments for your BMW, credit card payments for
Shekinah church members, and maintenance and utility payments for the Shekinah Parties
and their affiliates.
• On May 11, 2022, you and Robert barged into Ms. Leigh’s room at the Tujunga Property
to reprimand Ms. Leigh for something she had said to Robert the day before. Wearing your
boots, you forced your way into Ms. Leigh’s room, tore the room apart and ripped off the
scriptures she had on her walls. Simultaneously, while destroying her personal belongings,
you physically assaulted Ms. Leigh for over thirty minutes, hitting and pushing her with
your bare hands and kicking her, while yelling profanities meant to cause severe emotional
distress, such as “you don’t deserve God,” “you have no rights to being loved,” and
“nobody likes you.” Once you were done berating Ms. Leigh, you returned to her room
with Robert and continued with your emotional abuse for more than an hour.
After years of emotional and physical abuse and distress, Ms. Leigh had no choice but to
leave Shekinah with almost nothing. This letter shall serve as a formal demand that you provide
Ms. Leigh $5,000,000. In addition, Ms. Leigh demands the return of her personal belongings that
you stole, including but not limited to, her designer diamond and gold jewelry, bags, clothes, and
shoes. This represents a substantial discount on the amount that a jury would award Ms. Leigh for
emotional distress and punitive damages. In light of the circumstances surrounding this case, your
clear-cut liability, and your actions, which led to Ms. Leigh’s substantial damages, we presume
that you will not want to engage in protracted litigation.
Ms. Leigh would prefer to move on with her life, but if we do not receive a response from
you by 5:00 PM on October 28, 2022, Ms. Leigh will file a civil complaint against you.

October 18, 2022
Page 4
Sincerely,
Ethan J. Brown
Encl.
October 12, 2022
Robert Israel Shinn

royalyork78@yahoo.com
gigafir-glory@yahoo.com
4435 Camellia Ave.

191 E. City Place Dr.

Santa Ana, California 92705
7754 McGroarty St.

Tujunga, CA 91042
7744 McGroarty St.

Tujunga, CA 91042
7742 McGroarty St.

Tujunga, CA 91042
Dear Mr. Shinn:
connection with Shekinah Church and RCP Financial, Inc. At trial, you, Hannah Shinn, Matthew
Khloe Shinn, Daniel Joseph, Eung Seok Son (aka: Luke), Shekinah Church, Alpha Plus Realty
(“Alpha”), and RCP Financial, Inc. (“RCP”), Imaginating Pictures (collectively the “Shekinah
set forth more fully below. Ms. Leigh hereby demands $25 million to settle her claims before
filing a lawsuit.
It is hard to summarize the nearly twenty-three years of brainwashing, physical, sexual and
emotional abuse, manipulation, and exploitation to which you subjected Ms. Leigh. You referred
to yourself as “the Man of God” and preached to your church members that without you, they
would be cursed. You convinced Ms. Leigh and other church members that unless they fully
October 12, 2022
Page 2
submitted to you, their lives and the lives of their families would be destroyed, and that they would
go to hell. You specifically told them that if they did not submit to you, they would experience
poverty, sickness, and the death of their loved ones. You required church members to tell you
their deepest fears and secrets, and then manipulated them by saying that those fears would come
to pass if they did not submit to you. To you, full submission meant economic and physical
submission, which is how you justified the financial and sexual abuse set forth herein.
At your hands, Ms. Leigh lost priceless years of her life and at least millions of dollars.
The Shekinah Parties conspired to and did violate numerous financial and labor laws. Many of
the Shekinah Parties, including you, subjected Ms. Leigh to emotional abuse and humiliation. You
also routinely sexually assaulted and harassed Ms. Leigh while simultaneously siphoning her
income for your personal use and business ventures. Ms. Leigh has suffered extreme distress
because of the Shekinah Parties’ actions, and she intends to do whatever it takes to obtain redress
for what you have taken and done.
Financial Control
For decades, you completely controlled Ms. Leigh’s finances with the assistance of your
wife, Hannah Shinn. As a young woman from Korea in her late teens, vulnerable and abandoned
by her parents, Ms. Leigh was the perfect target for your growing church. You recruited her as a
member in 1999. Ms. Leigh stayed with the church in substantial part because she became
financially reliant on you. When Ms. Leigh first joined the church, she did not have a driver’s
license or a green card. When her driver’s license came in the mail, you kept it until she agreed to
join the church. You convinced her that the only reason she was able to obtain a license as an
undocumented person was because you had prayed for it and that, therefore, she owed you her life.
While she was undocumented, you had her work for two companies but instructed those companies
to make payments to a different church member. Ms. Leigh didn’t receive any of the funds sent
to that church member and instead received a small, weekly allowance in cash. And she had to
account for every purchase she made with that allowance, even chewing gum. Ms. Leigh was
young and did not have legal status to work here. After being indoctrinated and manipulated by
you, she felt afraid that she would be unable to make a living for herself any other way.
Ultimately, Ms. Leigh became a licensed real estate broker. For thirteen years, while she
made the Shekinah Parties millions of dollars as a real estate broker, you did not compensate Ms.
Leigh for her work. At first, she simply was not paid and instead was given a small cash allowance.
Later you paid her in part but into an account controlled by church members, such as Hannah Shinn
and Shirley Kim. The Shekinah Parties manipulated Ms. Leigh into believing that great harm
would come to her if she did not return almost all of her income to you and the church. You didn’t
depend upon manipulation alone –to ensure that Ms. Leigh provided the Shekinah Parties with her
October 12, 2022
Page 3
income, and presumably to avoid certain of the Shekinah Parties’ tax obligations, one of your
church members was always listed on her account. This gave the Shekinah Parties the ability to
control deposits and withdrawals from her account. Furthermore, you and your associates required
Ms. Leigh to take the extraordinary step of pre-signing checks that you would ultimately write to
the Shekinah Parties and their affiliates, including for the personal expenses of other persons.
None of this was properly reported to the tax authorities in tax returns prepared for Ms. Leigh by
the Shekinah Parties. A substantial portion of these funds was used to pay expenses Ms. Leigh
had nothing to do with and fund your companies, including by payments to Abraham Park, Kloe
Shinn, Daniel Joseph, Christina Keller, Lemuel Betton, Hannah Shinn, and other church members.
That is embezzlement.
In 2021, the Shekinah Parties, at your direction and with the help of Hannah Shinn,
Christina Keller, and Jenny Park, also took approximately $100,000 in COVID relief funds that
should have been paid to church members and instead prepaid many of Alpha’s expenses. You
also took some of these funds as cash and used them to pay personal expenses like your utility
bills. Not only did you fail to give any of these funds to Ms. Leigh, but you also stopped paying
her salary entirely for six months and took $800 per month in unemployment payments directed
to her for your own benefit.
The Shekinah Parties’ embezzlement of Ms. Leigh’s funds totals approximately $500,000.
This unprecedented control by an employer of its employee’s finances was not only immoral, but
it was also illegal.
Emotional Abuse
As if the financial control of Ms. Leigh was not enough, you also subjected her to emotional
abuse. Ms. Leigh managed to extricate herself from the church in 2004 and got married in March
2008. At that point, Ms. Leigh’s sisters were still involved in the church, and you used them to
reel her back in. Even when Ms. Leigh had left the church, you continued to monitor her through
her sisters. You told her sisters to remind Ms. Leigh that because she left the church she was out
of God’s grace and was going to hell or would die. This messaging caused Ms. Leigh severe
depression. After years of this manipulation while Ms. Leigh was not involved in the church, Ms.
Leigh’s sister (at your behest) called her in November 2008 and asked Ms. Leigh to meet with you.
When you met, you presented yourself to Ms. Leigh as a savior. You pressured her to file for
bankruptcy, divorce her husband at the time, and give her dogs away – presumably to make her
totally and utterly dependent on you. You took advantage of the fact Ms. Leigh was behind on her
bills and falsely promised her financial stability and salvation in exchange for her dedicating her
life to you, once again. Ms. Leigh worked for you as a real estate broker and was the broker of
record for Alpha and RCP. At that point, Ms. Leigh felt pressured to make money for you. You
claimed you had no money at the time but assured her that everything would be taken care of as
long as she worked. Ms. Leigh felt a sense of obligation to you.
October 12, 2022
Page 4
You would force Ms. Leigh to take part in actions to humiliate herself and punish her for
breaking your “rules.” She was repeatedly berated in front of other church members. You verbally
abused her and would often require hours of manual labor from her, for which you purposely
credited other individuals. In addition to the money you embezzled from her, you and members
of the church, forced her to surrender personal belongings worth approximately $500,000 as
punishment for trying to separate herself from your stronghold. First, in 2009, you showed up
unannounced with other church members including Daniel Joseph and Shirley Kim, to her
residence at 511 Green Acre Drive and packed her belongings and took them from her possession,
informing her that this was an instruction and disobedience would not be allowed. Designer bags,
designer clothes and shoes, jewelry, furniture, perfume, make up, kitchen appliances, and cash
were among the many items you confiscated at that time. Then in 2010, you and Hannah took all
of her belongings from her while she was living with other church members at Madison Circle in
Anaheim. You left with a car full of Ms. Leigh’s belongings. While you fed Ms. Leigh false
promises of hope, gifts, and heaven, you instead caused her to lose more than she could have ever
imagined.
Sexual Harassment and Assault
As with most of the dozens of women you lured into the church, you regularly sexually
harassed and assaulted Ms. Leigh. In addition to the financial and emotional manipulation, you
controlled her ability to engage in relationships with others. Having set up separate living quarters
for men and women, you required that the church approve any relationships Ms. Leigh was to have
with a man.
Knowing that her marriage was struggling, you started making unwelcomed sexual
advances to Ms. Leigh around 2009, even though you were married to someone else. You started
grooming her to have sex with you by coming to her home when she was alone and asking her to
massage your thighs. This continued for about one year and each time you ordered a massage you
instructed her to get closer and closer to your crotch. One day you went to the offices of what was
then Giga Financial, another of your companies. You ordered Ms. Leigh to go to the conference
room and remove her clothing so that you could see whether she had been losing weight. You
started touching her, put her hand on your crotch, first made her perform oral sex on you and then
made her have intercourse with you.
Between 2010 and 2011 Ms. Leigh was living in Tustin with other church members in a
home you owned. Multiple times a week you met Ms. Leigh there and ordered her to take a shower
with you, wash your body, and have oral and penetrative intercourse with you. Afterwards, she
had to return to work. You also subjected other women that lived there to the same routine, but at
different times of the week.
When you lived in Laguna Beach from 2011 to 2012, you coordinated the schedule of your
wife and children so that the house would be empty once a week. When the house was empty, you
October 12, 2022
Page 5
ordered her to visit you and shower with you, wash your body, have oral and penetrative
intercourse with you, and return to work, just as the case had been in Tustin.
The office for Alpha and RCP, located at 191 E. City Place in Santa Ana, had a bedroom
on the third floor, and you would come to the office during the workday and force Ms. Leigh to
engage in sexual acts with you as a condition of maintaining her employment. These sexual
advances so disturbed Ms. Leigh that she again left the church in 2012.
You coerced Ms. Leigh to have sex with you at a time in her life when you exerted so much
control over her that she truly had no free will. She left with nothing and became very sick,
experiencing anxiety attacks and depression so severe that she could not leave her house. You led
Ms. Leigh to believe she was being punished and going to hell. You told her you could only help
her if she returned to the church. So, she did.
After Ms. Leigh rejoined in 2014, you had Shirley Kim move into Ms. Leigh’s home in
Irvine and monitor her every move. You and Shirley had sex on Ms. Leigh’s bed while she was
at work. You took her BMW and gave her a Hyundai. Shirley added herself to Ms. Leigh’s bank
account, gave her no allowance, and demanded that Ms. Leigh ask permission for everything she
wanted to buy, including the food Ms. Leigh ate. Shirley often refused permission when Ms. Leigh
did ask. Shirley also took all of Ms. Leigh’s belongings including, makeup, clothes, furniture, and
kitchenware, and distributed them to other church members. Shirley replaced the items she took
from Ms. Leigh with used shoes and clothing from the other church members along with their
leftover makeup.
When Ms. Leigh returned to the church, she was told she had to marry Luke Son, who was
the janitor of Shekinah. Ms. Leigh refused because she was disgusted by him and found him
creepy. Regardless, for weeks in 2016, Ms. Leigh was ordered by Shirley Kim, at your direction,
to have intercourse with Luke. Ms. Leigh refused. Desperate to avoid having sex with Luke, she
told you and Shirley that she had a rash on her vagina.
Shortly thereafter, you went to see Ms. Leigh while she was working at City Place, where
Shirley was living on the 3rd floor. You took Ms. Leigh to Shirley’s bedroom, ordered her to
spread her legs, and saw that she didn't have a rash. Shirley was there while you inspected Ms.
Leigh. Shirley then ordered Ms. Leigh to go have sex with Luke at another church member’s home
in Orange and texted Ms. Leigh throughout to make sure it was happening. Ms. Leigh had never
felt so humiliated in her life. Shirley made Ms. Leigh believe that she had to do this in order to
get rid of depression and anxiety that she was suffering. Ms. Leigh later found out that you offered
Luke sex with Ms. Leigh in exchange for access to Luke’s family’s connections to a prominent
Korean entertainment company.
Your unwelcomed sexual advances on Ms. Leigh resumed in May 2020 at the home in
Tujunga where she was living and working. On that day you showed up unannounced, laid naked
October 12, 2022
Page 6
on her bed, and ordered her to have sex with you. This continued at least once a week until she
left Shekinah Church in May 2022.
Shinn Family, Shirley Kim, Christina Keller, Abraham Park, and Daniel Joseph
Through your direction, your wife, Hannah Shinn, controlled all the finances for Alpha,
RCP, and the church members’ banking accounts, including Ms. Leigh’s. She was responsible for
coordinating the logistics of the Shekinah Parties’ tax evasion and embezzlement. Your son, Isaiah
Shinn, assisted you in recruiting members to the church and knowingly received embezzled funds
from church members. Your daughter, Kloe Shinn, knew of your sexual abuse and harassment of
church members, and she also knowingly received embezzled funds. Shirley Kim is an attorney
who handles your production business, is a broker for Alpha, and most recently had some members
of your church sign an unconscionable NDA. Abraham Park and Shirley Kim are the legal owners
of 191 City Place Drive, where all the Shekinah businesses are registered. You also knowingly
received embezzled funds from church members. Until he left in May of 2022, Daniel Joseph was
your right-hand man and assisted you in all of your wrongdoings. These parties are directly liable
for many of the claims set forth below and for conspiracy to commit and aiding and abetting you
in committing the claims set forth below.
As you are aware, given your role in orchestrating them, there are many more wrongs the
Shekinah Parties committed against Ms. Leigh and other members of the church, which we have
not detailed here, but that would certainly be included in a lawsuit should you force Ms. Leigh to
file one.
I. LIABILITY
Below is a sampling of the causes of action Ms. Leigh will bring against the Shekinah
Parties.
A. FRAUD: INTENTIONAL MISREPRESENTATION, DECEIT, AND

CONCEALMENT
In California, fraud embraces anything intended to deceive, including all statements, acts,
concealments, and omissions involving the breach of a legal or equitable duty, trust, or confidence
that results in injury to one who justifiably relies thereon. Ach v. Finkelstein (1968) 264
Cal.App.2d 667. “One who willfully deceives another with intent to induce [them] to alter [their]
position to [their] injury or risk, is liable for any damage which [they] thereby suffer[].” Cal. Civ.
Code § 1709. Deceit is either: “(1) [t]he suggestion, as a fact, of that which is not true, by one
who does not believe it to be true; (2) [t]he assertion, as a fact, of that which is not true, by one
who has no reasonable ground for believing it to be true; (3) [t]he suppression of a fact, by one
who is bound to disclose it, or who gives information of other facts which are likely to mislead for
October 12, 2022
Page 7
want of communication of that fact; or (4) [a] promise, made without any intention of performing
it.” Cal. Civ. Code § 1710.
You represented that the funds you took from Ms. Leigh were for the church, which was
not, in fact, permitted as a church. Eventhen, the funds were not even used for Shekinah. Instead,
the funds were used to benefit you and members of your family personally. You made these
representations of material fact that were false and misleading and which Ms. Leigh relied upon
to her detriment. The truth was that you preyed on younger individuals, such as Ms. Leigh,
exposing them to a fraudulent scheme organized to manipulate them and take advantage of their
faith. You hid from Ms. Leigh that you simply intended to profit from her labor and her body, as
you have done with so many other young people. You concealed and suppressed these facts with
no intention of informing Ms. Leigh or others of your scheme. As a proximate consequence of
your wrongful acts against Ms. Leigh, she has suffered emotional distress and other general and
special damages.
B. INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
You are also liable to Ms. Leigh for intentional infliction of emotional distress. A cause
of action for intentional infliction of emotional distress exists when there is (1) extreme and
outrageous conduct by the defendant with the intention of causing, or reckless disregard of the
probability of causing, emotional distress; (2) the plaintiff’s suffering severe or extreme emotional
distress; and (3) actual and proximate causation of the emotional distress by the defendant’s
outrageous conduct. “A defendant’s conduct is ‘outrageous’ when it is so ‘extreme as to exceed
all bounds of that usually tolerated in a civilized community.’” CACI No. 1600; Hughes v. Pair
(2009) 46 Cal.4th 1035, 1050-1051.
For decades, you controlled every aspect of Ms. Leigh’s life, leading her toward exceeding
vulnerability and loss of self-identity. On multiple occasions, you engaged in acts of sexual assault
and coercion against Ms. Leigh. Regularly, you forced her to do things to humiliate herself and
punished her for breaking your rules or not following your instructions. You humiliated her in
front of other members of Shekinah. You fully intended to cause Ms. Leigh severe emotional
distress to manipulate her into fulfilling your wishes. You consistently threatened her with hell if
As a direct result of your wrongful conduct, Ms. Leigh sustained severe emotional distress and
pain, emotional anguish, fear, anxiety, humiliation, embarrassment, and other physical and
emotional injuries and damages that are substantial and continuing.
C. LABOR VIOLATIONS
The Shekinah Parties are also liable to Ms. Leigh for multiple labor violations. It is
unlawful for any employer to collect or receive from an employee any part of wages theretofore
paid by said employer to said employee. Cal. Lab. Code § 221. In actions for such a violation,
October 12, 2022
Page 8
reasonable attorney’s fees and costs are often awarded to the prevailing party. Cal. Lab. Code §
218.5. Moreover, whoever knowingly provides or obtains the services of a person by threats of
serious harm or by means of any scheme, plan, or pattern intended to cause the person to believe
that, if that person did not perform such labor or services, that person would suffer serious harm
shall face fines or imprisonment. 18 U.S.C. § 1589(a)–(d). Serious harm means “any harm,
whether physical or nonphysical, including psychological, financial, or reputational harm, that is
sufficiently serious, under all the surrounding circumstances, to compel a reasonable person of the
same background and in the same circumstances to perform or to continue performing labor or
services in order to avoid incurring that harm.” 18 U.S.C. § 1589(c)(2).
As part of your scheme, Ms. Leigh essentially performed uncompensated labor, working
many hours for little or no compensation for your benefit. She was pressured into performing
labor and personal services for you and other Shekinah Church members, where the value of her
labor was devalued, regardless of her skills. In exchange for her work, she was credited a small
rate or a nominal amount of money. When she was compensated for her work, you and other
members would withdraw large sums of money from her accounts that you and other members
controlled. You consistently threatened Ms. Leigh with hell, humiliation, or other punishment if
As a result, Ms. Leigh was consistently and reasonably in fear of serious harm if she did not follow
your instructions.
D. BREACH OF FIDUCIARY DUTY
The Shekinah Parties, including but not limited to you, Hannah Shinn, and Shirley Kim,
are also liable to Ms. Leigh for breach of fiduciary duty. A fiduciary relationship is created where
a person reposes trust and confidence in another, and the person in whom such confidence is
reposed obtains control over the other person's affairs. Richard B. LeVine, Inc. v. Higashi (2005)
131 Cal. App. 4th 566. A fiduciary relationship is a recognized legal relationship, and a fiduciary
must give priority to the best interest of the beneficiary; in addition to this duty of preference
toward the beneficiary, the fiduciary also is required to manage the subject matter of the
relationship with due care, must account to the beneficiary, and must keep the beneficiary fully
informed as to all matters pertinent to the beneficiary's interest. Oakland Raiders v. National
Football League (2005) 131 Cal. App. 4th 621. Similarly, a "confidential relationship" may be
founded on a moral, social, domestic, or merely personal relationship as well as on a legal
relationship. Persson v. Smart Inventions, Inc. (2005) 125 Cal.App.4th 1141. Punitive damages
may be awarded where a defendant is guilty of oppression, fraud, or malice, proven by clear and
convincing evidence. Cal. Civ. Code § 3294; see Michelson v. Hamada (1994) 29 Cal.App.4th
1566, 1582 (punitive damages appropriate for breach of fiduciary duty constituting constructive
fraud); see also Hobbs v. Bateman Eichler, Hill Richards, Inc. (1985) 164 Cal.App.3d 174, 194
(Cal. Civ. Code § 3294 applies to actions for breach of fiduciary duty).
October 12, 2022
Page 9
You, Hannah Shinn, and Shirley Kim had a fiduciary duty to Ms. Leigh based on your
control of her finances, and you breached that duty. Ms. Leigh’s financials were within the
Shekinah Parties’ control, and you failed to prioritize or even consider her best interests or manage
her financials with due care. Instead, you fraudulently and maliciously used her accounts as
another tool to control and manipulate Ms. Leigh. Instead of compensating Ms. Leigh for her
work, you coerced Ms. Leigh into pre-signing checks that you would ultimately write to the
Shekinah Parties and their affiliates, including for the personal expenses of other persons. For
example, on multiple occasions, Ms. Leigh’s bank accounts were used to pay for the rent of Shirley
Kim, Daniel Joseph, and Kloe Shinn. Additionally, Ms. Leigh’s accounts were used to make
monthly payments for Hannah Shinn’s BMW, credit card payments for Shekinah church members,
and maintenance and utility payments for the Shekinah Parties and their affiliates. You left Ms.
Leigh with a pitiful monthly allowance and did not even come close to complying with your
fiduciary duty to her.
E. SEXUAL HARASSMENT
In addition, you are also liable to Ms. Leigh for sexual harassment, which, under both Title
VII of the Civil Rights Act of 1964 and the Fair Employment and Housing Act (FEHA), is
considered a form of discrimination in employment. Under FEHA, “harassment” is defined as
“conduct outside the scope of necessary job performance, conduct presumably engaged in for
personal gratification, because of meanness or bigotry, or for other personal motives.” Reno v.
Baird (1998) 18 Cal.4th 640, 645. It is enough that the individual making the
unwelcome sexual advance was plaintiff's supervisor and that a link to employment benefits could
be inferred under the circumstances. Holly D. v. California Institute of Technology (9th Cir. 2003)
339 F.3d 1158, 1173. “Such a claim may lie either when continued employment has been
expressly conditioned on participation in sexual acts or when the supervisor's words or conduct
would communicate to a reasonable woman in the employee's position that such participation is a
condition of employment.” Id. (emphasis added). Further, if a party submitted to the advances
only out of fear of losing a job benefit, she can still state a claim for harassment. Meritor Sav.
Bank, FSB v. Vinson (1986) 477 U.S. 57, 68.
You were Ms. Leigh’s employer and supervisor at Giga, Alpha, and RCP. On multiple
occasions, you coerced Ms. Leigh to have sex with you at a time in her life when you exerted so
much control over her that she truly had no free will. You set up the business with a bedroom on
the third floor, and you would come to her business during the workday and force Ms. Leigh to
engage in sexual acts with you. You also forced Ms. Leigh to have sex with you at her home and
at your home while she was employed by you and your companies. The implication was that if
she did not have sex with you, she would lose her job and go to hell. After years of controlling
Ms. Leigh’s every action, she reasonably felt there was no option but to submit to your requests or
face being punished for disobedience.
October 12, 2022
Page 10
F. GENDER VIOLENCE
Additionally, your sexual relationship with Ms. Leigh was not consensual and therefore
constituted sexual assault. “Any person who has been subjected to gender violence may bring a
civil action for damages against any responsible party. The plaintiff may seek actual damages,
compensatory damages, punitive damages, injunctive relief, any combination of those, or any other
appropriate relief. A prevailing plaintiff may also be awarded attorney's fees and costs.” Cal. Civ.
Code, § 52.4(a). Gender violence is a form of sex discrimination and includes the use, attempted
use, or threatened use of physical force against the person or property of another, committed at
least in part based on the gender of the victim. Cal. Civ. Code § 52.4(c).
You controlled Ms. Leigh’s living arrangements, checking accounts, food intake, and every
aspect of her life, including her ability to enter into relationships. Having set up separate living
quarters for church members, you required that any relationships Ms. Leigh was to have with a
man be approved by the church. Because of your actions, set forth more fully above, Ms. Leigh
sustained severe emotional distress and physical pain, emotional anguish, fear, anxiety,
humiliation, embarrassment, and other physical and emotional injuries, as well as economic and
non-economic damages.
G. RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS ACT

(RICO)
In addition to fraud, the Shekinah Parties are liable to Ms. Leigh pursuant to RICO.
RICO makes it unlawful for any person to do the following acts with respect to an enterprise
engaged in, or affecting, interstate or foreign commerce: (a) to acquire an interest in, or the
establishment or operation of, the enterprise through the use of income derived from a pattern of
racketeering activity or collection of an unlawful debt; (b) to acquire or maintain an interest in, or
control of, the enterprise through a pattern of racketeering activity or collection of an unlawful
debt; (c) to conduct or participate in the conduct of the enterprise's affairs through a pattern of
racketeering activity or collection of an unlawful debt, where the person is employed by, or
associated with, the enterprise; (d) to conspire to do any of the aforementioned acts. 18 U.S.C., §
1962.
You conspired with members of your companies and church to operate and did, in fact,
operate a racketeering enterprise. Through this enterprise, you physically and psychologically
abused people and engaged in, among other wrongful acts, embezzlement, tax fraud, sexual abuse,
sexual harassment, forced labor, mail fraud, and wire fraud, bilking Ms. Leigh and others out of
large sums of money. Over time, you established multiple businesses, entities and groups through
which your enterprise could affect its scheme, achieve its objectives, bilk numerous Shekinah
Church members out of their hard earned money, establish and profit from businesses supported
by labor that was not paid in compliance with California laws, fraudulently obtain donations to a
fake “church”, avoid paying taxes, and engage in a myriad of other predicate racketeering acts.
October 12, 2022
Page 11
You knowingly managed and operated this enterprise, destroying numerous lives, including Ms.
Leigh’s, while enriching and aggrandizing yourself, maintaining a highly abusive environment
that enabled you to manipulate and coerce members into doing as you commanded for both
financial and psychological gain.
After years of hard work at your companies Ms. Leigh had not choice but to leave Shekinah
with almost nothing. This letter shall serve as a formal demand that you provide Ms. Leigh
$25,000,000. This represents a substantial discount on the amount that a jury would award Ms.
Leigh for emotional distress and punitive damages. In light of the circumstances surrounding this
case, your clear-cut liability, and your actions, which led to Ms. Leigh’s substantial damages, we
presume that you will not want to engage in protracted litigation.
Ms. Leigh would prefer to move on with her life, but if we do not hear back from you by
5:00 PM on October 21, 2022, Ms. Leigh will file a civil complaint against the Shekinah Parties.

Sincerely,
Ethan J. Brown
EXHIBIT C
Orange County Office
650 Town Center Drive, Suite 840
Costa Mesa, CA 92626
(714) 292-0262
epglawyers.com
DANIEL R. GUTENPLAN
(714) 656-3182
dgutenplan@epglawyers.com
October 20, 2022
VIA EMAIL ONLY
Ethan J. Brown
Brown, Neri, Smith & Khan LLP
11601 Wilshire Boulevard, Suite 2080
Los Angeles, CA 90025
Email: ethan@bnsklaw.com
Re: Elisha Priscylla Leigh Demand Letter
Dear Mr. Brown:
This firm is counsel for Shekinah Church, Robert Shinn, and Hannah Shinn, and we are
in the process of being retained in connection with the pre-litigation dispute with your client
Elisha Priscylla Leigh. Moving forward, please send all communications to my attention.
We are in receipt of your October 12, 2022 Demand Letter sent to Mr. Shinn, and I
understand that you have requested a response by the close of business tomorrow, October 21.
Further, we are in receipt of your October 18, 2022 Demand Letter sent to Ms. Shinn and your
October 19, 2022 Preservation Letter sent to Ms. Shinn and are requesting responses by October
28, 2022 and October 21, 2022, respectfully. Needless to say, the Demand Letters contains a
voluminous amount of information and allegations. Given that we have just received the letters
and are still in the process of being retained, we simply will not be in a position to respond
substantively by tomorrow. That said, I expect to be up to speed quickly and to send you a
formal response next week. If you have any questions in the interim, please do not hesitate to
reach out.
Nothing contained herein shall constitute a waiver of my clients’ rights or remedies, all of
which are expressly reserved.
Regards,
ENENSTEIN PHAM & GLASS LLP
___________________________________
By: Daniel R. Gutenplan
1 PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
I am employed in Los Angeles County, California. I am over the age of 18 and not a party to
3
this action; my business address is 11601 Wilshire Blvd., Suite 2080, Los Angeles,
4 California 90025. On the date below, I caused the following,
5 • DEFENDANT MELANIE LEE’S NOTICE OF MOTION AND SPECIAL MOTION TO STRIKE

PURSUANT TO CODE OF CIVIL PROCEDURE § 425.16; MEMORANDUM OF POINTS AND
6 AUTHORITIES
• DEFENDANT MELANIE LEE’S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF
7 SPECIAL MOTION TO STRIKE
• DECLARATION OF SARA C. COLÓN IN SUPPORT OF DEFENDANT MELANIE LEE’S
• DECLARATION OF NEGAR SAATCHI IN SUPPORT OF DEFENDANT MELANIE LEE’S
• DECLARATION OF DEFENDANT MELANIE LEE IN SUPPORT OF SPECIAL MOTION TO
10
STRIKE
• DECLARATION OF KYLIE DOUGLAS IN SUPPORT OF DEFENDANT MELANIE LEE'S SPECIAL
11
MOTION TO STRIKE
• DECLARATION OF KEVIN DAVIS IN SUPPORT OF DEFENDANT MELANIE LEE'S SPECIAL
12
MOTION TO STRIKE
13 • DECLARATION OF GORDON WATKINS IN SUPPORT OF DEFENDANT MELANIE LEE'S
SPECIAL MOTION TO STRIKE
14 • DECLARATION OF ALEXANDRA WATKINS IN SUPPORT OF DEFENDANT MELANIE LEE’S
15 • DECLARATION OF AUBREY FISHER-GREENE IN SUPPORT OF DEFENDANT MELANIE LEE’S
16 • [PROPOSED] ORDER ON DEFENDANT MELANIE LEE’S SPECIAL MOTION TO STRIKE
17
to be served by email to the following addresses:
18
19 Daniel R. Gutenplan (dgutenplan@epglawyers.com)

Lauren B. Shelby (lshelby@epglawyers.com)
20 Philip M. Duclos (pduclos@epglawyers.com)
21
ENENSTEIN PHAM & GLASS
650 Town Center Drive, Suite 840
22 Costa Mesa, CA 92626
23
Attorneys for Plaintiffs
24
X BY ELECTRONIC MAIL: I caused such document(s) to be electronically mailed in
25 PDF format as an e-mail attachment to each addressee for the above-entitled case. The
transmission was complete and confirmed. A copy of the transmittal e-mail will be
26 maintained with the original document(s) in our office.
27 I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct. Executed on December 6, 2022, at Albany, New York.
28
________________________
Kete Barnes
PROOF OF SERVICE

Demand Letter To Robert Shinn & Hannah Shinn

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Demand Letter To Robert Shinn & Hannah Shinn

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Electronically FILED by Superior Court of California, County of Los Angeles on 12/06/2022 04:23 PM Sherri R.

Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk

1 Ethan J. Brown (SBN 218814)

DECLARATION OF SARA C. COLÓN

OMNIBUS REQUEST FOR JUDICIAL NOTICE

Via Email and U.S. Mail

Robert Israel Shinn

4435 Camellia Ave.

191 E. City Place Dr.

7754 McGroarty St.

7744 McGroarty St.

7742 McGroarty St.

RE: Elisha Priscylla Leigh Demand Letter

Dear Mr. Shinn:

Sexual Harassment and Assault

A. FRAUD: INTENTIONAL MISREPRESENTATION, DECEIT, AND

B. INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

D. BREACH OF FIDUCIARY DUTY

G. RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS ACT

II. SETTLEMENT DEMAND

This is a confidential settlement demand as contemplated under California Evidence Code

Via Email and U.S. Mail

4435 Camellia Ave.

191 E City Place Dr

RE: Elisha Priscylla Leigh Demand Letter

Dear Ms. Shinn:

B. AIDING AND ABETTING

II. SETTLEMENT DEMAND

This is a confidential settlement demand as contemplated under California Evidence Code

Via Email and U.S. Mail

Robert Israel Shinn

4435 Camellia Ave.

191 E. City Place Dr.

7754 McGroarty St.

7744 McGroarty St.

7742 McGroarty St.

RE: Elisha Priscylla Leigh Demand Letter

Dear Mr. Shinn:

Sexual Harassment and Assault

A. FRAUD: INTENTIONAL MISREPRESENTATION, DECEIT, AND

B. INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

D. BREACH OF FIDUCIARY DUTY

G. RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS ACT

II. SETTLEMENT DEMAND

This is a confidential settlement demand as contemplated under California Evidence Code

Re: Elisha Priscylla Leigh Demand Letter

Dear Mr. Brown:

ENENSTEIN PHAM & GLASS LLP

5 • DEFENDANT MELANIE LEE’S NOTICE OF MOTION AND SPECIAL MOTION TO STRIKE

19 Daniel R. Gutenplan (dgutenplan@epglawyers.com)

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