Shawn Thompson v. City of Manhattan Beach, Steve Kitsios, and Shane Smith

• Court: District Court, C.D. California
• Decided: October 6, 2025
• Docket: 2:24-cv-03479
• Status: Unknown

Opinion

11 James R. Touchstone, Esq., SBN 184584 jrt@jones-mayer.com 22 JONES MAYER 3777 North Harbor Boulevard 33 Fullerton, California 92835 Tel (714) 446-1400; Fax (714) 446-1448 44 Attorney for Defendant, 55 Shawn Thompson (Application for substitution pending)

66 Steven J. Rothans, Esq. SBN 106579 srothans@crdlaw.com 77 Kimberly Sarmiento, Esq. SBN 345641 ksarmiento@cardlaw.com 88 CARPENTER, ROTHANS, & DUMONT, LLP 500 South Grand Avenue, 19th Floor 99 Los Angeles, CA 90071 Tel (714) 228-0400; Fax (714) 228-0401 1100 Attorneys for Defendants, City of Manhattan 1111 Beach, Steve Kitsios, and Shane Smith

1122 Alexis Galindo, Esq. SBN 136643 agalindo@cgsattys.com 1133 Maximiliano Galindo, Esq. SBN 328187 mgalindo@cgsattys.com 1144 CURD, GALINDO, & SMITH, LLP 301 East Ocean Blvd., Suite 1700 1155 Long Beach, CA 90802-4828 Tel (562) 624-1177; Fax (562) 624-1178 1166 Attorneys for Plaintiff, 1177 Mason Lewis

1188 UNITED STATES DISTRICT COURT

1199 FOR THE CENTRAL DISTRICT OF CALIFORNIA

2211 MASON LEWIS, Case No: 2:24-cv-03479-WLH-RAO Plaintiff, 2222 Assigned for all purposes to: vs. Hon. Wesley L. Hsu; Courtroom 9D 2233 CITY OF MANHATTAN BEACH, STIPULATED PROTECTIVE 2244 SHAWN THOMPSON, STEVE ORDER KITSIOS, SHANE SMITH, and 2255 DOES 1 through 20, Inclusive;

2266 Defendants.

2277 11 1. A. PURPOSES AND LIMITATIONS

22 Discovery in this action is likely to involve production of confidential, 33 proprietary or private information for which special protection from public 44 disclosure and from use for any purpose other than prosecuting this litigation may 55 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 66 enter the following Stipulated Protective Order. The parties acknowledge that this 77 Order does not confer blanket protections on all disclosures or responses to 88 discovery and that the protection it affords from public disclosure and use extends 99 only to the limited information or items that are entitled to confidential treatment 1100 under the applicable legal principles. 1111 1122 B. GOOD CAUSE STATEMENT 1133 This action is likely to involve confidential information from the Manhattan 1144 Beach Police Department’s criminal investigation and records from Plaintiff 1155 Mason Lewis’s parallel criminal proceedings for which special protection from 1166 public disclosure and from use for any purpose other than prosecution of this 1177 action is warranted. Such confidential and proprietary materials and information 1188 consist of, among other things, investigative materials, witness interviews, data 1199 extractions and reports, and other information otherwise generally unavailable to 2200 the public, or which may be privileged or otherwise protected from disclosure 2211 under state or federal statutes, court rules, case decisions, or common law. 2222 Accordingly, to expedite the flow of information, to facilitate the prompt resolution 2233 of disputes over confidentiality of discovery materials, to adequately protect 2244 information the parties are entitled to keep confidential, to ensure that the parties 2255 are permitted reasonable necessary uses of such material in preparation for and in 2266 the conduct of trial, to address their handling at the end of the litigation, and serve 2277 the ends of justice, a protective order for such information is justified in this

matter. It is the intent of the parties that information will not be designated as 11 confidential for tactical reasons and that nothing be so designated without a good

22 faith belief that it has been maintained in a confidential, non-public manner, and 33 there is good cause why it should not be part of the public record of this case. 44 55 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 66 SEAL 77 The parties further acknowledge, as set forth in Section 12.3, below, that 88 this Stipulated Protective Order does not entitle them to file confidential 99 information under seal; Local Civil Rule 79-5 sets forth the procedures that must 1100 be followed and the standards that will be applied when a party seeks permission 1111 from the court to file material under seal. 1122 There is a strong presumption that the public has a right of access to judicial 1133 proceedings and records in civil cases. In connection with non-dispositive 1144 motions, good cause must be shown to support a filing under seal. See Kamakana 1155 v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. 1166 Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. 1177 Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 1188 protective orders require good cause showing), and a specific showing of good 1199 cause or compelling reasons with proper evidentiary support and legal justification, 2200 must be made with respect to Protected Material that a party seeks to file under 2211 seal. The parties’ mere designation of Disclosure or Discovery Material as 2222 CONFIDENTIAL does not—without the submission of competent evidence by 2233 declaration, establishing that the material sought to be filed under seal qualifies as 2244 confidential, privileged, or otherwise protectable—constitute good cause. 2255 Further, if a party requests sealing related to a dispositive motion or trial, 2266 then compelling reasons, not only good cause, for the sealing must be shown, and 2277 the relief sought shall be narrowly tailored to serve the specific interest to be

protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 11 2010). For each item or type of information, document, or thing sought to be filed

22 or introduced under seal in connection with a dispositive motion or trial, the party 33 seeking protection must articulate compelling reasons, supported by specific facts 44 and legal justification, for the requested sealing order. Again, competent evidence 55 supporting the application to file documents under seal must be provided by 66 declaration. 77 Any document that is not confidential, privileged, or otherwise protectable 88 in its entirety will not be filed under seal if the confidential portions can be 99 redacted. If documents can be redacted, then a redacted version for public 1100 viewing, omitting only the confidential, privileged, or otherwise protectable 1111 portions of the document shall be filed. Any application that seeks to file 1122 documents under seal in their entirety should include an explanation of why 1133 redaction is not feasible. 1144 1155 2. DEFINITIONS 1166 2.1 Action: Mason Swan Lewis v. City of Manhattan Beach, et al., CV24- 1177 03479-WLH-RAOx and Mary Swan Lewis v. City of Manhattan Beach, et al., 1188 2:23-cv-03319-WLH-RAO. 1199 2.2 Challenging Party: a Party or Non-Party that challenges the 2200 designation of information or items under this Order. 2211 A. 2.3 “CONFIDENTIAL” Information or Items: information 2222 (regardless of how it is generated, stored or maintained) or tangible 2233 things that qualify for protection under Federal Rule of Civil Procedure 2244 26(c), and as specified above in the Good Cause Statement. 2255 B. 2.4 Counsel: Outside Counsel of Record and House Counsel 2266 (as well as their support staff). 2277 C. 2.5 Designating Party: a Party or Non-Party that designates

information or items that it produces in disclosures or in responses to 11 discovery as “CONFIDENTIAL.”

22 D. 2.6 Disclosure or Discovery Material: all items or 33 information, regardless of the medium or manner in which it is generated, 44 stored, or maintained (including, among other things, testimony, 55 transcripts, and tangible things) that are produced or generated in 66 disclosures or responses to discovery in this matter. 77 E. 2.7 Expert: a person with specialized knowledge or 88 experience in a matter pertinent to the litigation who has been retained by 99 a Party or its counsel to serve as an expert witness or as a consultant in 1100 this Action. 1111 F. 2.8 House Counsel: attorneys who are employees of a party 1122 to this Action. House Counsel does not include Outside Counsel of 1133 Record or any other outside counsel. 1144 G. 2.9 Non-Party: any natural person, partnership, corporation, 1155 association or other legal entity not named as a Party to this action. 1166 H. 2.10 Outside Counsel of Record: attorneys who are not 1177 employees of a party to this Action but are retained to represent or advise 1188 a party to this Action and have appeared in this Action on behalf of that 1199 party or are affiliated with a law firm that has appeared on behalf of that 2200 party, and includes support staff. 2211 I. 2.11 Party: any party to this Action, including all of its 2222 officers, directors, employees, consultants, retained experts, and Outside 2233 Counsel of Record (and their support staffs). 2244 J. 2.12 Producing Party: a Party or Non-Party that produces 2255 Disclosure or Discovery Material in this Action. 2266 K. 2.13 Professional Vendors: persons or entities that provide 2277 litigation support services (e.g., photocopying, videotaping, translating,

preparing exhibits or demonstrations, and organizing, storing, or 11 retrieving data in any form or medium) and their employees and

22 subcontractors. 33 L. 2.14 Protected Material: any Disclosure or Discovery 44 Material that is designated as “CONFIDENTIAL.” 55 M. 2.15 Receiving Party: a Party that receives Disclosure or 66 Discovery Material from a Producing Party. 77 88 3. SCOPE 99 The protections conferred by this Stipulation and Order cover not only 1100 Protected Material (as defined above), but also (1) any information copied or 1111 extracted from Protected Material; (2) all copies, excerpts, summaries, or 1122 compilations of Protected Material; and (3) any testimony, conversations, or 1133 presentations by Parties or their Counsel that might reveal Protected Material. 1144 Any use of Protected Material at trial shall be governed by the orders of the 1155 trial judge. This Order does not govern the use of Protected Material at trial. 1166 1177 4. DURATION 1188 Once a case proceeds to trial, information that was designated as 1199 CONFIDENTIAL or maintained pursuant to this protective order used or 2200 introduced as an exhibit at trial becomes public and will be presumptively 2211 available to all members of the public, including the press, unless compelling 2222 reasons supported by specific factual findings to proceed otherwise are made to the 2233 trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 2244 (distinguishing “good cause” showing for sealing documents produced in 2255 discovery from “compelling reasons” standard when merits-related documents are 2266 part of court record). Accordingly, the terms of this protective order do not extend 2277 beyond the commencement of the trial. 11 5. DESIGNATING PROTECTED MATERIAL

22 N. 5.1 Exercise of Restraint and Care in Designating Material 33 for Protection. Each Party or Non-Party that designates information or 44 items for protection under this Order must take care to limit any such 55 designation to specific material that qualifies under the appropriate 66 standards. The Designating Party must designate for protection only 77 those parts of material, documents, items or oral or written 88 communications that qualify so that other portions of the material, 99 documents, items or communications for which protection is not 1100 warranted are not swept unjustifiably within the ambit of this Order. 1111 Mass, indiscriminate or routinized designations are prohibited. Designations 1122 that are shown to be clearly unjustified or that have been made for an improper 1133 purpose (e.g., to unnecessarily encumber the case development process or to 1144 impose unnecessary expenses and burdens on other parties) may expose the 1155 Designating Party to sanctions. 1166 If it comes to a Designating Party’s attention that information or items that it 1177 designated for protection do not qualify for protection, that Designating Party must 1188 promptly notify all other Parties that it is withdrawing the inapplicable designation. 1199 O. 5.2 Manner and Timing of Designations. Except as 2200 otherwise provided in this Order (see, e.g., second paragraph of section 2211 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or 2222 Discovery Material that qualifies for protection under this Order must be 2233 clearly so designated before the material is disclosed or produced. 2244 Designation in conformity with this Order requires: 2255 P. (a) for information in documentary form (e.g., paper or 2266 electronic documents, but excluding transcripts of depositions or other 2277 pretrial or trial proceedings), that the Producing Party affix at a

minimum, the legend “CONFIDENTIAL” (hereinafter 11 “CONFIDENTIAL legend”), to each page that contains protected

22 material. If only a portion of the material on a page qualifies for 33 protection, the Producing Party also must clearly identify the protected 44 portion(s) (e.g., by making appropriate markings in the margins). 55 A Party or Non-Party that makes original documents available for inspection 66 need not designate them for protection until after the inspecting Party has indicated 77 which documents it would like copied and produced. During the inspection and 88 before the designation, all of the material made available for inspection shall be 99 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 1100 documents it wants copied and produced, the Producing Party must determine 1111 which documents, or portions thereof, qualify for protection under this Order. 1122 Then, before producing the specified documents, the Producing Party must affix 1133 the “CONFIDENTIAL legend” to each page that contains Protected Material. If 1144 only a portion of the material on a page qualifies for protection, the Producing 1155 Party also must clearly identify the protected portion(s) (e.g., by making 1166 appropriate markings in the margins). 1177 Q. (b) for testimony given in depositions that the 1188 Designating Party identifies the Disclosure or Discovery Material on the 1199 record, before the close of the deposition all protected testimony. 2200 R. (c) for information produced in some form other than 2211 documentary and for any other tangible items, that the Producing Party 2222 affix in a prominent place on the exterior of the container or containers in 2233 which the information is stored the legend “CONFIDENTIAL.” If only a 2244 portion or portions of the information warrants protection, the Producing 2255 Party, to the extent practicable, shall identify the protected portion(s). 2266 S. 5.3 Inadvertent Failures to Designate. If timely corrected, an 2277 inadvertent failure to designate qualified information or items does not,

standing alone, waive the Designating Party’s right to secure protection 11 under this Order for such material. Upon timely correction of a

22 designation, the Receiving Party must make reasonable efforts to assure 33 that the material is treated in accordance with the provisions of this 44 Order. 55 66 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 77 T. 6.1 Timing of Challenges. Any Party or Non-Party may 88 challenge a designation of confidentiality at any time that is consistent 99 with the Court’s Scheduling Order. 1100 U. 6.2 Meet and Confer. The Challenging Party shall initiate 1111 the dispute resolution process under Local Rule 37.1 et seq. 1122 6.3 The burden of persuasion in any such challenge proceeding shall be 1133 on the Designating Party. Frivolous challenges, and those made for an improper 1144 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 1155 parties) may expose the Challenging Party to sanctions. Unless the Designating 1166 Party has waived or withdrawn the confidentiality designation, all parties shall 1177 continue to afford the material in question the level of protection to which it is 1188 entitled under the Producing Party’s designation until the Court rules on the 1199 challenge. 2200 2211 7. ACCESS TO AND USE OF PROTECTED MATERIAL 2222 V. 7.1 Basic Principles. A Receiving Party may use Protected 2233 Material that is disclosed or produced by another Party or by a Non-Party 2244 in connection with this Action only for prosecuting, defending or 2255 attempting to settle this Action. Such Protected Material may be 2266 disclosed only to the categories of persons and under the conditions 2277 described in this Order. When the Action has been terminated, a

Receiving Party must comply with the provisions of section 13 below 11 (FINAL DISPOSITION).

22 W. Protected Material must be stored and maintained by a 33 Receiving Party at a location and in a secure manner that ensures that 44 access is limited to the persons authorized under this Order. 55 X. 7.2 Disclosure of “CONFIDENTIAL” Information or Items. 66 Unless otherwise ordered by the court or permitted in writing by the 77 Designating Party, a Receiving Party may disclose any information or 88 item designated “CONFIDENTIAL” only to: 99 Y. (a) the Receiving Party’s Outside Counsel of Record in 1100 this Action, as well as employees of said Outside Counsel of Record to 1111 whom it is reasonably necessary to disclose the information for this 1122 Action, including insurance adjusters and their employees; 1133 Z. (b) the officers, directors, and employees (including 1144 House Counsel) of the Receiving Party to whom disclosure is reasonably 1155 necessary for this Action; 1166 AA. (c) Experts (as defined in this Order) of the Receiving 1177 Party to whom disclosure is reasonably necessary for this Action and 1188 who have signed the “Acknowledgment and Agreement to Be Bound” 1199 (Exhibit A); 2200 BB. (d) the court and its personnel; 2211 CC. (e) court reporters and their staff; 2222 DD. (f) professional jury or trial consultants, mock jurors, 2233 and Professional Vendors to whom disclosure is reasonably necessary for 2244 this Action and who have signed the “Acknowledgment and Agreement 2255 to Be Bound” (Exhibit A); 2266 EE. (g) the author or recipient of a document containing the 2277 information or a custodian or other person who otherwise possessed or

knew the information; 11 FF. (h) during their depositions, witnesses, and attorneys for

22 witnesses, in the Action to whom disclosure is reasonably necessary 33 provided: (1) the deposing party requests that the witness sign the form 44 attached as Exhibit A hereto; and (2) they will not be permitted to keep 55 any confidential information unless they sign the “Acknowledgment and 66 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the 77 Designating Party or ordered by the court. Pages of transcribed 88 deposition testimony or exhibits to depositions that reveal Protected 99 Material may be separately bound by the court reporter and may not be 1100 disclosed to anyone except as permitted under this Stipulated Protective 1111 Order; and 1122 GG. (i) any mediator or settlement officer, and their 1133 supporting personnel, mutually agreed upon by any of the parties 1144 engaged in settlement discussions. 1155 HH. (j) any non-retained experts who are expected to testify in 1166 this litigation. 1177 1188 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 1199 IN OTHER LITIGATION 2200 II. If a Party is served with a subpoena or a court order issued in 2211 other litigation that compels disclosure of any information or items 2222 designated in this Action as “CONFIDENTIAL,” that Party must: 2233 JJ. (a) promptly notify in writing the Designating Party. 2244 Such notification shall include a copy of the subpoena or court order; 2255 KK. (b) promptly notify in writing the party who caused the 2266 subpoena or order to issue in the other litigation that some or all of the 2277 material covered by the subpoena or order is subject to this Protective

Order. Such notification shall include a copy of this Stipulated Protective 11 Order; and

22 LL. (c) cooperate with respect to all reasonable procedures 33 sought to be pursued by the Designating Party whose Protected Material 44 may be affected. 55 MM. If the Designating Party timely seeks a protective order, 66 the Party served with the subpoena or court order shall not produce any 77 information designated in this action as “CONFIDENTIAL” before a 88 determination by the court from which the subpoena or order issued, 99 unless the Party has obtained the Designating Party’s permission. The 1100 Designating Party shall bear the burden and expense of seeking 1111 protection in that court of its confidential material and nothing in these 1122 provisions should be construed as authorizing or encouraging a 1133 Receiving Party in this Action to disobey a lawful directive from another 1144 court. 1155 1166 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 1177 PRODUCED IN THIS LITIGATION 1188 NN. (a) The terms of this Order are applicable to information 1199 produced by a Non-Party in this Action and designated as 2200 “CONFIDENTIAL.” Such information produced by Non-Parties in 2211 connection with this litigation is protected by the remedies and relief 2222 provided by this Order. Nothing in these provisions should be construed 2233 as prohibiting a Non-Party from seeking additional protections. 2244 OO. (b) In the event that a Party is required, by a valid 2255 discovery request, to produce a Non-Party’s confidential information in 2266 its possession, and the Party is subject to an agreement with the Non- 2277 Party not to produce the Non-Party’s confidential information, then the

Party shall: 11 PP. (1) promptly notify in writing the Requesting

22 Party and the Non-Party that some or all of the information requested is 33 subject to a confidentiality agreement with a Non-Party; 44 55 QQ. (2) promptly provide the Non-Party with a copy of 66 the Stipulated Protective Order in this Action, the relevant discovery 77 request(s), and a reasonably specific description of the information 88 requested; and 99 RR. (3) make the information requested available for 1100 inspection by the Non-Party, if requested. 1111 SS. (c) If the Non-Party fails to seek a protective order from 1122 this court within 14 days of receiving the notice and accompanying 1133 information, the Receiving Party may produce the Non-Party’s 1144 confidential information responsive to the discovery request. If the Non- 1155 Party timely seeks a protective order, the Receiving Party shall not 1166 produce any information in its possession or control that is subject to the 1177 confidentiality agreement with the Non-Party before a determination by 1188 the court. Absent a court order to the contrary, the Non-Party shall bear 1199 the burden and expense of seeking protection in this court of its Protected 2200 Material. 2211 2222 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2233 TT. If a Receiving Party learns that, by inadvertence or 2244 otherwise, it has disclosed Protected Material to any person or in any 2255 circumstance not authorized under this Stipulated Protective Order, the 2266 Receiving Party must immediately (a) notify in writing the Designating 2277 Party of the unauthorized disclosures, (b) use its best efforts to retrieve

all unauthorized copies of the Protected Material, (c) inform the person or 11 persons to whom unauthorized disclosures were made of all the terms of

22 this Order, and (d) request such person or persons to execute the 33 “Acknowledgment and Agreement to Be Bound” that is attached hereto 44 as Exhibit A. 55 66 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 77 PROTECTED MATERIAL 88 UU. When a Producing Party gives notice to Receiving 99 Parties that certain inadvertently produced material is subject to a claim 1100 of privilege or other protection, the obligations of the Receiving Parties 1111 are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This 1122 provision is not intended to modify whatever procedure may be 1133 established in an e-discovery order that provides for production without 1144 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 1155 (e), insofar as the parties reach an agreement on the effect of disclosure 1166 of a communication or information covered by the attorney-client 1177 privilege or work product protection, the parties may incorporate their 1188 agreement in the stipulated protective order submitted to the court. 1199 2200 12. MISCELLANEOUS 2211 VV. 12.1 Right to Further Relief. Nothing in this Order 2222 abridges the right of any person to seek its modification by the Court in 2233 the future. 2244 12.2 Right to Assert Other Objections. By stipulating to the entry of this 2255 Protective Order, no Party waives any right it otherwise would have to object to 2266 disclosing or producing any information or item on any ground not addressed in 2277 this Stipulated Protective Order. Similarly, no Party waives any right to object on 11 any ground to use in evidence of any of the material covered by this Protective

22 Order. 33 WW. 12.3 Filing Protected Material. A Party that seeks to 44 file under seal any Protected Material must comply with Local Civil Rule 55 79-5. Protected Material may only be filed under seal pursuant to a court 66 order authorizing the sealing of the specific Protected Material at issue. 77 If a Party’s request to file Protected Material under seal is denied by the 88 court, then the Receiving Party may file the information in the public 99 record unless otherwise instructed by the court. 1100 1111 13. FINAL DISPOSITION 1122 XX. After the final disposition of this Action, as defined in 1133 paragraph 4, within 60 days of a written request by the Designating Party, 1144 each Receiving Party must return all Protected Material to the Producing 1155 Party or destroy such material. As used in this subdivision, “all Protected 1166 Material” includes all copies, abstracts, compilations, summaries, and 1177 any other format reproducing or capturing any of the Protected Material. 1188 Whether the Protected Material is returned or destroyed, the Receiving 1199 Party must submit a written certification to the Producing Party (and, if 2200 not the same person or entity, to the Designating Party) by the 60 day 2211 deadline that (1) identifies (by category, where appropriate) all the 2222 Protected Material that was returned or destroyed and (2) affirms that the 2233 Receiving Party has not retained any copies, abstracts, compilations, 2244 summaries or any other format reproducing or capturing any of the 2255 Protected Material. Notwithstanding this provision, Counsel are entitled 2266 to retain an archival copy of all pleadings, motion papers, trial, 2277 deposition, and hearing transcripts, legal memoranda, correspondence,

deposition and trial exhibits, expert reports, attorney work product, and 11 consultant and expert work product, even if such materials contain

22 Protected Material. Any such archival copies that contain or constitute 33 Protected Material remain subject to this Protective Order as set forth in 44 Section 4 (DURATION). 55 66 77 88 99 1100 1111 1122 1133 1144 1155 1166 1177 1188 1199 2200 2211 2222 2233 2244 2255 2266 2277 11 IT IS SO STIPULATED 22 33 Dated: October 2, 2025 JONES & MAYER 44 By:/s/ Helen O. Kim 55 JAMES R. TOUCHSTONE HELEN 66 O. KIM Attorney for Defendant SHAWN 77 THOMPSON 88 99 1100 Dated: October 2, 2025 CURD, GALINDO & SMITH, LLP 1111 1122 By: ____/s/ Alexis Galindo__________ 1133 ALEXIS GALINDO MAXIMILIANA GALINDO Attorneys for Plaintiff 1144 MASON LEWIS 1155 1166 1177 1188 1199 2200 2211 2222 2233 2244 2255 2266 2277 | CARPENTER, ROTHANS, & 2 Dated: October 2, 2025 DUMONT, LLP 4 By:/s/ Kimberly Sarmiento 5 STEVEN J. ROTHANS KIMBERLY SARMIENTO 6 Attorneys for Defendants CITY OF 7 MANHATTAN BEACH, STEVE KITSIOS, and SHANE SMITH 9 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 10 DATED: 10/6/2025

12 Rapli, , OC HON. ROZELLA A. OLIVER 13 || United States Magistrate Judge 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

11 EXHIBIT A

22 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 33 44 I, _____________________________ [print or type full name], of 55 _________________ [print or type full address], declare under penalty of perjury 66 that I have read in its entirety and understand the Stipulated Protective Order that 77 was issued by the United States District Court for the Central District of California 88 on [date] in the case of Mason Swan Lewis v. City of Manhattan Beach, et al., 99 CV24-03479-WLH-RAOx. I agree to comply with and to be bound by all the 1100 terms of this Stipulated Protective Order and I understand and acknowledge that 1111 failure to so comply could expose me to sanctions and punishment in the nature of 1122 contempt. I solemnly promise that I will not disclose in any manner any 1133 information or item that is subject to this Stipulated Protective Order to any person 1144 or entity except in strict compliance with the provisions of this Order. 1155 I further agree to submit to the jurisdiction of the United States District Court for 1166 the Central District of California for enforcing the terms of this Stipulated 1177 Protective Order, even if such enforcement proceedings occur after termination of 1188 this action. I hereby appoint __________________________ [print or type full 1199 name] of _______________________________________ [print or type full 2200 address and telephone number] as my California agent for service of process in 2211 connection with this action or any proceedings related to enforcement of this 2222 Stipulated Protective Order. 2233 Date: ______________________________________ 2244 City and State where sworn and signed: _________________________________ 2255 2266 Printed name: _______________________________ 2277

Signature: __________________________________