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

2200

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).

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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

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| 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

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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: __________________________________