 Amid mounting evidence which led to the belief that Kozminski could have faked his death to avoid paying Holocaust survivors, Kalmansohn filed civil suits against Kozminski on behalf of Weingarten and Wolman.In 1999, Los Angeles County Superior Court Judge John W. Ouderkirk ruled that Kozminski's death certificate was false and/or fraudulent and that Kozminski may still be alive.In 2000, a second judge concurred in the earlier finding.