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IN THE SUPERIOR COURT OF THE STATE OF SAN ANDREAS COUNTY OF LOS SANTOS CIVIL DIVISION TZOMPAXTLE, Plaintiff, v. LOS SANTOS POLICE DEPARTMENT Defendants. Case No. 25-LSC-05121 ───────────── NOTICE OF EX PARTE APPLICATION AND MOTION ───────────── Ibraheem A. Davis, State Bar No. 081000067 [email protected] 1578 Station Ave, 2nd Floor Los Santos, San Andreas 90071 179-9901 Attorney for Defendant LOS SANTOS POLICE DEPARTMENT TABLE OF CONTENTS I. INTRODUCTION.............................................................................................................. II. JURISDICTION................................................................................................................ III. FACTUAL BACKGROUND............................................................................................ IV. LEGAL ARGUMENT....................................................................................................... A. Authority of Relief.................................................................................................... B. There is Good Cause and No Prejudice.................................................................... C. Substantial Compliance and Judicial Economy....................................................... V. CONCLUSION................................................................................................................. PLEASE TAKE NOTICE that Defendant Los Santos Police Department ("LSPD") will and hereby does apply ex parte to the Honorable Francis J. Stoessel on May 19, 2025, (or as soon thereafter as the matter may be heard), for an order pursuant to Code of Civil Procedure § 473 (d) and the Court's inherent authority, granting relief nunc pro tunc from the service deadline of May 10, 2025, and the proof-of-service deadline of May 12, 2025, as set forth in this Court's Order to Show Cause dated May 4, 2025. This Application is brought on the grounds of inadvertent calendaring error, excusable neglect, and absence of prejudice to Plaintiff, and is based on this Notice, the attached Memorandum of Points and Authorities, the accompanying Declaration of Chief Counsel, and the entire record in this action. MEMORANDUM OF POINTS AND AUTHORITIES I. INTRODUCTION ᅠᅠ Defendant LSPD respectfully requests that the Court exercise its equitable powers and statutory authority under CCP § 473 (d) to excuse and sanitize the late service and late proof of service of LSPD's Opposition to the OSC. Due to an internal calendaring oversight, the Opposition and supporting exhibits, though fully prepared by the requisite deadline, were not served or filed until May 17, 2025. This brief delay has not prejudiced Plaintiff. Accordingly LSPD seeks an order deeming service of the Opposition and exhibits timely as of May 10, 2025, and deeming the Proof of Service timely as of May 12, 2025. Such relief serves the interests of justice by avoiding hyper-technical forfeiture and focusing the litigation on the substantive issues. II. JURISDICTION ᅠᅠ This Court has jurisdiction under the San Andreas Constitution and the Code of Civil Procedure, including but not limited to Code Civ. Proc. § 410.10 and 42 U.S.C § 1983. III. FACTUAL BACKGROUND ᅠᅠ 1. On May 4, 2025, this Court issued an Order to Show Cause requiring Defendant to serve its Opposition to the OSC and supporting papers by May 10, 2025, and to file Proof of Service by May 12, 2025. 2. LSPD's counsel timely completed drafting of the Opposition brief, the Declaration of Sgt. Bates, and all supporting exhibits by no later than May 10, 2025. 3. An inadvertent administrative calendaring error caused counsel to overlook the service and proof deadlines. As a result, no documents were served or filed by the respective deadlines. 4. Upon discovering the rror on May 17, 2025, LSPD's counsel immediately served the Opposition package, including the ex parte application, on Plaintiff's counsel and is now filing the necessary Proof of Service. 5. Plaintiff has received all materials, has not requested continuance and has suffered no prejudice or tactical disadvantage due to the five-day delay in service. III. LEGAL ARGUMENT ᅠᅠ A. Authority of Relief CCP § 473 (d) authorized the Court to relieve a party from procedural default cause by inadvertent mistake or excusable neglect. Courts routinely grant relief where a part demonstrates a clerical or calendaring mistake and absence of prejudice to the opposing party (Bank of America v. Ross (1984)) Here, counsel's error was inadvertent and not motivated by bad faith or intentional disregard of the Court's mandates. B. There Is Good Cause and No Prejudice Good cause for relief exists when the failure to serve or file timely was the result of inadvertent clerical error. Courts consider whether the delay prejudiced the opposing party; in this case, Plaintiff has had full access to all Opposition materials since May 17, 2025, and has not indicated any inability to respond or adverse impact on preparation. Under these circumstances, equitable considerataions weigh in favor of granting relief. C. Substantial Compliance and Judicial Economy LSPD substantially complied with the OSC by preparing all required filings and exhibits by the deadlines, and by promptly serving them upon discovery of the oversight. Enforcing a harsh sanction for such minimal delay would waste judicial resources and distract from the core merits, namely, the clarity of Vehicle Code § 502, and the validity of Sgt. Bates' lawful order under PC § 610 (b). An order granting relief promotes judicial efficinecy and respects the parties' substantive rights. III. LEGAL ARGUMENT WHEREFORE, Defendant respectfully requests that the Court: 1. GRANT relief under CCP § 473 (d) nunc pro tunc, treating service of LSPD's Opposition to the Order to Show Cause as timely on May 10, 2025; 2. DEEM the Proof of Service timely filed nunc pro tunc on May 12, 2025; 3. EXTEND or re-set any deadlines for replies or further briefing at the Court's discretion; and 4. GRANT such other and further relief as the Court may deem just and proper. DATED: May 17, 2025 By: /s/ Ibraheem A. Davis Ibraheem A. Davis Chief Counsel LOS SANTOS POLICE DEPARTMENT (( ATTACHED DECLARATION)) I, Ibraheem A. Davis, Chief Counsel for the Los Santos Police Department, declare under penalty of perjury: 1. The Legal Affairs Section ("LAS") prepared and finalized the Opposition to the Order to Show Cause and all supporting exhibits by May 10, 2025. 2. Due to an inadvertent calendaring oversight within my officer's case management system, the documents were not served or filed until May 17, 2025. 3. I immediately took corrective action by serving the materials on Plaintiff's counsel and preparing the instant ex parte application. 4. To my knowledge, Plaintiff has received all filings and suffered no prejudice. 5. I respectfully request that the Court exercise its discretion and grant relief pursuant to CCP § 473 (d). Executed on May 17, 2025, at Los Santos, San Andreas. Ibraheem A. Davis Chief Counsel LOS SANTOS POLICE DEPARTMENT

** Proof of Service updated via E-File ** (( ))

IN THE SUPERIOR COURT OF THE STATE OF SAN ANDREAS COUNTY OF LOS SANTOS CIVIL DIVISION TZOMPAXTLE, Plaintiff, v. LOS SANTOS POLICE DEPARTMENT Defendants. Case No. 25-LSC-05121 ───────────── DEFENDANT'S OPPOSITION TO ORDER TO SHOW CAUSE ───────────── Ibraheem A. Davis, State Bar No. 081000067 [email protected] 1578 Station Ave, 2nd Floor Los Santos, San Andreas 90071 179-9901 Attorney for Defendant LOS SANTOS POLICE DEPARTMENT TABLE OF CONTENTS I. INTRODUCTION.............................................................................................................. II. JURISDICTION................................................................................................................ III. FACTUAL BACKGROUND............................................................................................ IV. LEGAL STANDARD........................................................................................................ V. LEGAL ARGUMENT......................................................................................................... A. LSPD Has Fully Complied with the Court's Directive............................................ B. Vehicle Code § 502 Is Clear and Requires No Interpretation................................... C. Penal Code § 601 (b) Authorizes the Arrest............................................................. D. Plaintiff's Habeas and Speedy-Trial Claims Are Inappropriate Here....................... E. Judicial Economy Favors Quashing or Deeming the OSC Satisfied....................... VI. CONCLUSION................................................................................................................. I. INTRODUCTION ᅠᅠ Defendant Los Santos Police Department ("LSPD") by and through counsel, respectfully submits this Opposition to the order to Show Cause issued by this Court on May 4, 2025. In that Order, Plaintiff Juan Tzompaxtle seeks two distinct forms of relief: (1) the immediate production of all evidentiary materials supporting Plaintiff's arrest under Penal Code § 610 (b), including the arrest affidavit and in-car recordings; and (2) declaratory relief interpreting Vehicle Code § 502's requirements for headlight usage. Contrary to Plaintiff's assertions, LSPD has satisfied the Court's discovery directive by providing the Declaration of Sergeant Travis Bates (Exhibit A) and the exhibits identified below. Moreover, the relevant statutes, Vehicle Code § 502 and Penal Code § 610 (b), both speak with sufficient clarity under well-established precedent, and Plaintiff's request for declaratory relief is neither necessary nor appropriate. Finally, Plaintiff's extended foray into habeas and speedy-trial arguments exceeds the scope of this civil proceeding and falls squarely outside LSPD's authority. For these reasons the Court should deem the OSC satisfied, quash it, and deny any further relief. II. JURISDICTION ᅠᅠ This Court has jurisdiction under the San Andreas Constitution and the Code of Civil Procedure, including but not limited to Code Civ. Proc. § 410.10 and 42 U.S.C § 1983. III. FACTUAL BACKGROUND ᅠᅠ 1. First Traffic Stop (May 3, 2025) On May 3, 2025, at approximately 21:30 hours, shortly after street lamps had been activated, Sergeant Travis Bates (serial #41082) observed a white Burrito (license plate 9XER151) traveling without headlights in violation of Vehicle Code § 502. Recognizing the public-safety hazard, he safely conducted a traffic stop at the intersection of Main and Hill. 2. Citation and Verbal order Sergeant Bates approached the driver, identified himself as an LSPD Sergeant, and requested license and proof of insurance. After confirming the vehicle lacked insurance (VC 301) and headlights (VC 502), he issued citations for both infractions. Before releasing the driver, he clearly communicated a lawful directive: 3. Second Traffic Stop & Arrest (May 3, 2025) Approximately ten minutes later, in the area of Central Street near Station, Sergeant Bates observed the same Burrito still operating without headlights despite ongoing street-lamp illumination. He initiated a second stop, reminded Plaintiff of the prior order, and, upon Plaintiff's willful refusal, effected an arrest under Penal Code § 610 (b) for failure to obey a lawful order. Lieutenant Sebastian Knox provided assistance during the arrest/ 4. Evidentiary Record The entirety of both stops and the arrest was captured on Sergeant Bate's in-car digital video (DICV) system. The recordings document: a. Street lamps clearly activated b. Absence of vehicle headlights c. Citations being issued d. The verbal directive and Plaintiff's refusal ("I do not need them. Thank you for the advice though".) e. The subsequent detention and arrest process. All footage and the transcript are stored with an unbroken chain of custody and available for the Court's review. IV. LEGAL STANDARD ᅠᅠ An Order to Show Cause is not a fishing expedition; it compels the production of specified evidence only where the moving party demonstrates a particularized need and relevance to the claims or defenses (Doe v. Superior Court). When evidentiary materials are already in hand and the underlying legal issues are clear, additional relief is unwarranted. The Court's inherent authority to manage discovery must be balanced against the interests of efficiency, finality, and equitable administration of justice. V. LEGAL ARGUMENT ᅠᅠ A. LSPD Has Fully Complied with the Court's Directive LSPD has produced the exact materials enumerated in the OSC: 1. Exhibit A Declaration of Sergeant Travis Bates, detailing qualifications, training, and firsthand observations. 2. Exhibit B DICV footage of both traffic stops. 3. Exhibit C The sworn arrest affidavit under PC 610 (b) 4. Exhibit D Verbatim transcript of the DICV audio recordings. These exhibits even though delayed indisputable satisfy the OSC's requirement to produce the arrest affidavit and video evidence. Plaintiff's demand for additional production is moot. B. Vehicle Code § 502 Is Clear and Requires No Interpretaion 1. Plain-Text Clarity Section 502 provides This dual-prong definition leaves no room for conflicting interpretations: "darkness" encompasses both the temporal window of sunset to sunrise and the objective condition of illuminated street lamps or adverse weather. 2. Precedent Support Dual-Prong Statutes San Andreas courts have routinely upheld statutes with layered requirements where each serves the Legislature's safety objectives (People v. Smith); (People v. Jones). 3. Public Safety Rationale The inclusion of street-lamp activation as an independent trigger reflects a common-sense approach to roadside safety: Officers and drivers rely on visible lighting conditions, not abstract sunset times. C. Penal Code § 601 (b) Authorizes the Arrest 1. Statutory Language PC 610 (b) provides 2. Lawful Order Established Sergeant Bates' directive to turn on headlights was grounded in VC 502 and communicated with precision. Under well-settled law, a verbal command based on statutory authority constitutes a "lawful order" (People v. Wilson). 3. Willful Non-Compliance Plaintiff's refusal, after being afforded notice and opportunity, met the threshold for willful defiance, justifying arrest. This is not a case of ambiguous discretion but of deliberate choice. D. Plaintiff's Habeas and Speedy-Trial Claims Are Inappropriate Here Plaintiff's Show Cause expansive prayer seeks reversal of criminal charges via writ of habeas corpus and speedy-trial relief. Such remedies lie exclusively within the criminal process and are typically pursued by a defendant in custody against the prosecuting agency. LSPD, as one of the enforcing arms of law, lacks authority to dismiss or expedite prosecutions, a role reserved for the District Attorney's Office or the Court in a criminal proceeding. E. Judicial Economy Favors Quashing or Deeming the OSC Satisfied Requiring further production or any declaratory ruling would waste judicial resources and unfairly burden LSPD and the Court. All responsive materials are before the Court, and the legal questions presented are straightforward. In the interest of judicial economy and finality, the Court should quash the complaint or simply deem LSPD in full compliance. VI. CONCLUSION ᅠᅠ For the foregoing reasons, Defendant Los Santos Police Department respectfully requests that this Court: 1. DEEM the Order to Show Cause satisfied or quash it in its entirety; 2. DENY any request for declaratory relief regarding Vehicle Code § 502; and 3. DISMISS Plaintiff's habeas and speedy-trial claims for lack of standing and jurisdiction DATED: May 17, 2025 By: /s/ Ibraheem A. Davis Ibraheem A. Davis Chief Counsel LOS SANTOS POLICE DEPARTMENT EXHIBIT A EXHIBIT B (( Can be sent via PMs )) EXHIBIT C EXHIBIT D (( Can be sent via PMs ))

Subject: Response to Clarification Request From: [email protected] CC: Juan Tzompaxtle, Esq. Dear Judge Stoessel, Pursuant to this Court's Order dates May 8, 2025, Defendants hereby supplement their prior discovery production with the Department's Notice of Termination of Police Officer II Bob Boulevard (REF CF No, 25-13426), attached under seal as Exhibit H. This exhibit reflects the final disciplinary action taken following sustained findings in the Internal Affairs investigation. All materials remain subject to the Protective Order and retain the designation "CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER". Defendants trust this supplementation fully satisfies the Court's discovery directives. Thank you for Your Honor's time and consideration Respectfully submitted, /s/ Ibraheem A. Davis Ibraheem Davis Chief Counsel LOS SANTOS POLICE DEPARTMENT REF: 25-LSC-04116 EXHIBIT H

Subject: Response to Clarification Request From: [email protected] CC: Juan Tzompaxtle, Esq. Dear Judge Stoessel, I write on behalf of Defendant Los Santos Police Department ("LSPD") in the matter of Saucedo v. Los Santos Police Department, et al. Case No. 25-LSC-04116, currently pending before Your Honor. Pursuant to Plaintiff's request for clarification regarding Exhibits B, C, F, Defendants attach the following affidavits and revised exhibit: 1. Exhibit B-1 Affidavit of Captain Steve Miller — Commanding Officer, Internal Affairs Group Confirms that Police Officer II Bob Boulevard has only the single Internal Affairs case already produced in Exhibit B, initiated in response to this lawsuit. 2. Exhibit C-1 Affidavit of Commander Isaac Gilbert — Commanding Officer, In-Service Training Group Explains the archival limitation for Officer Boulevard's early-career training records and provides a complete recertification timeline through January 2025. 3. Exhibit F-1 Dated Department Memorandum on Constitutional Filming Guidance The same memo previously produced as Exhibit F, now revised to show an issuance date of April 21, 2025. Thank you for Your Honor's time and consideration Respectfully submitted, /s/ Ibraheem A. Davis Ibraheem Davis Chief Counsel LOS SANTOS POLICE DEPARTMENT REF: 25-LSC-04116 EXHIBIT B-1 EXHIBIT C-1

IN THE SUPERIOR COURT OF THE STATE OF SAN ANDREAS COUNTY OF LOS SANTOS CIVIL DIVISION MICHELLE JEFFERSON, Plaintiff, v. LOS SANTOS POLICE DEPARTMENT, AND OFFICER GREGORY HUNTINGTON Defendants. Case No. 25-LSC-04119 ───────────── DEFENDANT'S OPPOSITION TO PLAINTIFF'S MOTION FOR SUMMARY JUDGEMENT AND CROSS-MOTION FOR SUMMARY JUDGEMENT ───────────── Ibraheem A. Davis, State Bar No. 081000067 [email protected] 1578 Station Ave, 2nd Floor Los Santos, San Andreas 90071 179-9901 Attorney for Defendant LOS SANTOS POLICE DEPARTMENT TABLE OF CONTENTS I. INTRODUCTION............................................................................................................. II. JURISDICTION................................................................................................................ III. STATEMENT OF FACTS & RESPONSES TO SPECIFIC ALLEGATIONS................. A. Undisputed Facts........................................................................................................... B. Plaintiff's Allegations and Defendants' Responses........................................................ IV. AFFIRMATIVE DEFENSES............................................................................................ V. CONCLUSION.................................................................................................................. I. INTRODUCTION ᅠᅠ Defendant Los Santos Police Department ("LSPD"), by and through counsel, respectfully submits this Opposition to Plaintiff's Motion for Summary Judgement and submits a Cross-Motion For Summary Judgement. Plaintiff Michelle Jefferson's Complaint alleges that Officer Gregory Huntington violated her First Amendment rights by issuing a threat of arrest and ordering her to cease interaction while she recorded a lawful traffic stop. These allegations, however, rest on a fundamental misunderstanding of both the facts and the contours of constitutional law. First, the incident at issue occurred against the backdrop of this Court's recent Mendoza decision, which expressly recognized the right to record police activity in public spaces. In direct response to Mendoza, LSPD issued a department-wide memorandum on April 21, 2025, days before the encounter, reaffirming officers' duty to respect constitutional rights, detailing permissible safety-based distance limitations, and prohibiting threats or arrests for lawful recording. All sworn personnel, including Officer Huntington, electronically acknowledged this guidance. Second, on April 27, 2025, Jefferson approaches Officer Huntington at an approximate distance of two to three feet, well within an unsafe proximity given the high-traffic environment, and loudly insulted him. Officer Huntington responded verbally, first requesting that she "back off" for safety reasons and then warning "I'll arrest you on God" when she refused. Importantly, Jefferson remained unrestrained, continued filming without interruption, and audibly counted down in defiance, demonstrating the absence of any chilling effect on her speech. Third, LSPD's swift issuance of the April 21 memorandum and Officer Huntington's subsequent voluntary resignation on April 28, 2025, underscore that his conduct was neither sanctioned by departmental policy nor indicative of a patter of indifference. Thus, not only did no constitutional violation occur, but there also exists no basis for municipal liability or punitive relief. Based on these facts and controlling precedent, including Colten v. Kentucky, Glik v. Cunniffe, and Saucier v. Katz, Defendants respectfully request that the Court deny Plaintiff's Motion for Summary Judgement and grant Defendants' Cross-Motion for Summary Judgement. II. JURISDICTION ᅠᅠ This Court has jurisdiction under the San Andreas Constitution and the Code of Civil Procedure, including but not limited to Code Civ. Proc. § 410.10 and 42 U.S.C § 1983. III. STATEMENT OF FACTS & RESPONSES TO SPECIFIC ALLEGATIONS ᅠᅠ A. Undisputed Facts 1. Traffic Stop Location and Conditions On April 27, 2025, Officer Huntington conducted a routine traffic stop on Artesia Avenue near Altura Street. This area is densely populated with both vehicles, pedestrians as well as increased gang activity, creating potential safety hazards if unauthorized persons approach too closely. 2. Plaintiff's Proximity and Recording Jefferson approached from the sidewalk, positioning her smartphone within two to three feet of Huntington's torso. She loudly directed derogatory language at him, calling him a "disrespectful punk", while continuing to record. 3. Verbal Commands by Officer Huntington Video and transcript show Huntington first responding "okay", then stating, "You have to back off". When Jefferson responded "You got something to say?", Huntington replied "Seriously". Upon her defiant "Try me", the officer warned, "I'll arrest you on God". These directives were verbal only and issued in the interest of officer and public safety. 4. Continued Filming and Defiance Un-arrested and unimpeded, Jefferson audibly counted "Five, Four, Three...", to mock the threat, then maintained her recording. 5. Officer Disengagement A radio transmission interrupted; Huntington stated, "You are a lucky person", and promptly went towards his patrol vehicle for an urgent call, leaving the site without any physical enforcement or follow-up. 6. No Physical Restraint At no time was Jefferson handcuffed, detained, or deprived of her equipment. She freely left the scene once Huntington departed. 7. April 21, 2025 Constitutional Rights Memorandum After Mendoza, Chief Andrew Antonelli issued a "Constitutional Rights" memorandum summarizing: a) The constitutional right to record law enforcement in public b) Permissible safety directives requiring reasonable distance c) Prohibition on arrest for lawful recording absent interference All sworn personnel electronically acknowledged receipt. 8. Officer Huntington's Resignation Huntington voluntarily resigned effective April 28, 2025 B. Plaintiff's Allegations and Defendant's Responses Paragraph 1: Admitted that Jefferson recorded on April 27, 2025. Admitted that recording is protected activity. Denied that any constitutional right was interfered with. Paragraph 2: Denied. Huntington's instructions were narrowly tailored, content-neutral safety measures consistent with Colten v. Kentucky, 407 U.S 103. The threat of arrest was conditional and never effectuated. Paragraph 2: Admitted that § 1983 does not require formal arrest (Barna v. Bd. of Sch. Directors), but denied any deprivation occurred. Paragraph 4: Denied. No punitive-damages basis exists against the municipality (Newport v. Fact Concerts, 453 U.S 247) or the officer who displayed no malice or reckless disregard (Smith v. Wade, 461 U.S 30) Paragraph 4: Denied. LSPD's prompt issuance of the April 21 memorandum negates any inference of deliberate indifference required for a Monell claim (Connick v. Thompson, 563 U.S 51; Pembaur v. Cincinnati, 475 U.S 469) IV. AFFIRMATIVE DEFENSES ᅠᅠ 1. Failure to State a Claim The Complaint fails to allege facts constituting a constitutional violation. Jefferson's recording was uninterrupted and no enforceable threat materialized. 2. Qualified Immunity Officer Huntington is protected under Harlow v. Fitzgerald, 457 U.S 800, unless his actions violated a clearly established right; no such precedent exists for narrowly tailored safety warnings during a traffic stop. 3. No Monell Liability LSPD cannot be held liable absent policy, custom or deliberate indifference. The April 21 memorandum constitutes valid policy guidance. 4. No Respondeat Superior Municipal liability under § 1983 does not extend to respondeat superior claims. 5. No Constitutional Violation Huntington's safety-based instructions were lawful. 6. No Causation Any alleged injury was not proximately cause by Defendants 7. Adequate Training LSPD's training materials and April 21 Memorandum demonstrate comprehensive First Amendment instruction. 8. No Chilling Effect Jefferson's continue filming and verbal defiance confirm absence of any chilling effect (Mendocino Environmental Ctr. 192 F.3d 1283). 9. Mootness Officer Huntington's resignation renders injunctive relief moot (Lyons, 461 U.S 95) 10. Punitive Damages Barred Punitive damages are barred against municipalities and require high culpability against individuals (Smith v. Wade, 461 U.S 30) 11. Plaintiff's Contributory Conduct Plaintiff's own provocative behavior justified Officer Huntington's narrow directives. V. CONCLUSION ᅠᅠ WHEREFORE, Defendants respectfully pray that this Court: 1. DENY Plaintiff's Motion for Summary Judgement in its entirety; 2. GRANT Defendants' Cross-Motion for Summary Judgement; 3. DISMISS Plaintiff's Complaint with prejudice; 4. AWARD Defendants' costs of suit and reasonable attorneys' fees; and 5. GRANT Any further relief the Court deems just and proper DATED: May 14, 2025 By: /s/ Ibraheem A. Davis Ibraheem A. Davis Chief Counsel LOS SANTOS POLICE DEPARTMEN

Subject: Request for In Camera Review From: [email protected] CC: Juan Tzompaxtle, Esq. Dear Judge Stoessel, I write on behalf of Defendant Los Santos Police Department ("LSPD") in the matter of Montblanc v. Shakhzadov, Case No. 25-LSC-04117, currently pending before Your Honor. Pursuant to Court's May 9, 2025 Order granting in part Plaintiff's Motion to Compel, the Department is preparing to produce certain sensitive materials including: Internal Affairs investigation files concerning former Officer A. Shakhzadov and personnel involved in the Media Card decision; Application records for News Media Identification Cards submitted between January 1, 2025 and April 30, 2025; Current department policies, procedures and training materials on citizen recording, press interaction, and credentialing processes. These records contain personal identifiers, preliminary investigatory notes, and deliberative content that implicate legitimate privacy and safety interests. To protect these interests while fully complying with Court's directive, the Department respectfully requests permission to submit these documents in camera for Your Honor's review. We will deliver a sealed package to the Clerk's Office (or upload via a secure electronic portal) by May 16, 2025. Should the Court require any specific filing format or protective protocols for in camera review, please advice and we will implement them immediately. Thank you for Your Honor's time and consideration Respectfully submitted, /s/ Ibraheem A. Davis Ibraheem Davis Chief Counsel LOS SANTOS POLICE DEPARTMENT REF: 25-LSC-04117

IN THE SUPERIOR COURT OF THE STATE OF SAN ANDREAS COUNTY OF LOS SANTOS CIVIL DIVISION ALAN SAUCEDO, Plaintiff, v. LOS SANTOS POLICE DEPARTMENT, et al. Defendants. Case No. 25-LSC-04117 ───────────── DEFENDANT'S DISCOVERY COMPLIANCE ───────────── Ibraheem A. Davis, State Bar No. 081000067 [email protected] 1578 Station Ave, 2nd Floor Los Santos, San Andreas 90071 179-9901 Attorney for Defendant LOS SANTOS POLICE DEPARTMENT EXHIBIT A - Officer Identification Police Officer II Bob Boulevard, Serial No. 41665 EXHIBIT B - Internal Affairs Files (Unredacted) (( CHATLOG FROM INTERVIEW I CAN SEND OVER FORUM PM AS IT IS TOO LONG )) EXHIBIT C - Officer's Boulevard Training & Certification History EXHIBIT D - Use-Of-Force Training Materials EXHIBIT E - Affidavit, CO of Professional Standards Bureau, Use-of-Force Incidents Summary EXHIBIT F - Department's Memorandum on Constitutional Obligations EXHIBIT G - Affidavit, CO of In-Service Training Group, Observation of Outside Police Perimeter and Public Filming EXHIBIT H - IA Questions sent to Plaintiff on May 1, 2025

IN THE SUPERIOR COURT OF THE STATE OF SAN ANDREAS COUNTY OF LOS SANTOS CIVIL DIVISION ALAN SAUCEDO, Plaintiff, v. LOS SANTOS POLICE DEPARTMENT, et al. Defendants. Case No. 25-LSC-04117 ───────────── RESPONSE TO PLAINTIFF'S MOTION FOR DEFAULT JUDGEMENT, SANCTIONS, AND IMPOUNDMENT ───────────── Ibraheem A. Davis, State Bar No. 081000067 [email protected] 1578 Station Ave, 2nd Floor Los Santos, San Andreas 90071 179-9901 Attorney for Defendant LOS SANTOS POLICE DEPARTMENT TABLE OF CONTENTS I. INTRODUCTION............................................................................................................. II. JURISDICTION................................................................................................................ III. FACTUAL BACKGROUND........................................................................................... IV. LEGAL ARGUMENT....................................................................................................... A. No Willful Disobedience or Bad Faith Exists...................................................... B. Sanctions or Default Judgement Would Be Procedurally and Substantively Improper........................,,,,,....................................................................................... C. Plaintiff's Request for Data Seizure and Impoundment is Extreme and Unwarranted........ V. CONCLUSION................................................................................................................. I. INTRODUCTION ᅠᅠ TO THE HONORABLE COURT AND TO PLAINTIFF AND HER COUNSEL OF RECORD: PLEASE TAKE NOTICE that Defendant, Los Santos Police Department ("LSPD") by and through counsel, submit this Response to Plaintiff's Motion for Default Judgement, Sanctions, and Impoundment filed on May 7, 2025. While Defendants acknowledge a delay in producing discovery in compliance with the Court's May 1, 2025 Order, such delay was not the result of bad faith, willful disobedience, or any intent to undermine judicial authority. Discovery production has now been completed in full, and Defendants respectfully request this Court deny Plaintiff's extreme requests and permit the matter to proceed on the merits. II. JURISDICTION ᅠᅠ This Court has jurisdiction under the San Andreas Constitution and the Code of Civil Procedure, including but not limited to Code Civ. Proc. § 410.10 and 42 U.S.C § 1983. III. FACTUAL BACKGROUND ᅠᅠ On May 1, 2025, this Court issued an Order compelling Defendants to produce seven categories of discovery and prohibiting closure of the internal affairs (IA) investigation without providing written questions and a response period to Plaintiff. Defendants promptly issued IA-related questions to Plaintiff on May 1, 2025. However due to internal administrative oversight and miscommunication regarding redaction procedures, full discovery was not transmitted by the May 6, 2025, deadline. As of May 9, 2025, Defendants have fully produced all ordered discovery, including: 1. Identification of the involved officer (Exhibit A) 2. Unredacted IA records (Exhibit B) 3. Full training and recertification records (Exhibit C) 4. Current use-of-force training materials (Exhibit D) 5. Affidavit from the Professional Standards Bureau summarizing use-of-force reports (Exhibit E) 6. Departmental statement on First Amendment obligations (Exhibit F) 7. Affidavit from the In-Service Training Group on perimeter and scene management (Exhibit G) All materials are appropriately labeled "CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER". A Certificate of Compliance as been filed concurrently. IV. LEGAL ARGUMENT ᅠᅠ A. No Willful Disobedience or Bad Faith Exists Courts may impose sanctions under Rule 37 only where a party has willfully disobeyed an order or acted in bad faith. Here, Defendants acted in good faith throughout. The delay was not evasive or strategic, but instead stemmed from internal coordination issues. The Department immediately complied once the delay was discovered, and no lasting prejudice to Plaintiff exists. B. Sanctions or Default Judgement Would Be Procedurally and Substantively Improper Default judgement is the most extreme remedy available under civil procedure, reserved for litigants who have intentionally obstructed proceedings. In Shen v. Department of Health (2002), 41 San.App.4th 721 held that even where discovery is delayed, good faith compliance cures procedural error unless prejudice is shown. Here, Plaintiff has suffered no actual harm, and now possesses all documents ordered. C. Plaintiff's Request for Data Seizure and Impoundment Is Extreme and Unwarranted Plaintiff's request to authorize the Los Santos Sheriff's Department to impound digital servers and seize internal personnel files is unprecedented, disproportionate, and unsupported by controlling law. There is no finding of contempt, no protective order violation, and no evidence that Defendants destroyed, altered, or withheld data in bad faith. Permitting external forensic inspection of LSPD's systems would raise grave privacy, chain of custody, and separation-of-powers concerns, particularly in the absence of any spoliation or discovery abuse. V. CONCLUSION ᅠᅠ Defendants take this Court's orders seriously and acknowledge the delay in production. However, as of May 9, 2025, Defendants have fully complied with the Court's May 1, Order, producing all compelled materials marked and delivered as required. A Certificate of Compliance has been filed. Further, Defendants note that while the Court required Plaintiff to be provided written Internal Affairs questions and afforded no fewer than ten(10) calendar days to respond before the investigation could close, Plaintiff has declined to answer those questions and instead submitted them under seal with an objection. As of May 9, 2025, no substantive answers have been received, and the ten-day window is set to expire on May 11, 2025, at which point the injunction automatically lapses per the Court's own terms. In light of full compliance by Defendants and noncompliance by Plaintiff, no prejudice has occurred. Defendants respectfully request that Court: 1. DENY Plaintiff's Motion for Default Judgement 2. DENY Plaintiff's request for sanctions or contempt proceedings 3. DENY Plaintiff's request for data seizure or impoundment 4. CONFIRM that the Court's May 1, 2025 Order has been satisfied. 5. AUTHORIZE closure of the Internal Affairs investigation if no further responses are received from Plaintiff by May 11, 2025. DATED: May 09, 2025 By: /s/ Ibraheem A. Davis Ibraheem A. Davis Chief Counsel LOS SANTOS POLICE DEPARTMENT

IN THE SUPERIOR COURT OF THE STATE OF SAN ANDREAS COUNTY OF LOS SANTOS CIVIL DIVISION MONTBLANC, Plaintiff, v. LOS SANTOS POLICE DEPARTMENT, OFFICER AKHMAD SHAKHZADOV (ret.), et al. Defendants. Case No. 25-LSC-04117 ───────────── DEFENDANTS' NOTICE OF MOTION AND MOTION TO DISMISS PLAINTIFF'S COMPLAINT IN ITS ENTIRETY [FRCP 12(b)(6)] ───────────── Ibraheem A. Davis, State Bar No. 081000067 [email protected] 1578 Station Ave, 2nd Floor Los Santos, San Andreas 90071 179-9901 Attorney for Defendant LOS SANTOS POLICE DEPARTMENT TABLE OF CONTENTS I. INTRODUCTION............................................................................................................. II. JURISDICTION................................................................................................................ III. FACTUAL BACKGROUND........................................................................................... IV. LEGAL ARGUMENT....................................................................................................... A. The Complaint Fails to Plausibly Allege Municipal Liability................................. B. The Retaliatory Denial of the Media Card Is Not Casually Connected to a Constitutional Violation............................................................................................................... C. Claims Against the Department Must Still Meet Federal Pleading Standards........ D. Individual Liability Remains with the Officer, Not the Department....................... V. CONCLUSION................................................................................................................. I. INTRODUCTION ᅠᅠ TO THE HONORABLE COURT AND TO PLAINTIFF AND HER COUNSEL OF RECORD: PLEASE TAKE NOTICE that Defendant, Los Santos Police Department ("LSPD") by and through counsel, hereby move this Court to dismiss Plaintiff Laura Montblanc's Complaint in its entirety pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure on the ground that Plaintiff fails to state a claim upon which relief can be granted. II. JURISDICTION ᅠᅠ This Court has jurisdiction under the San Andreas Constitution and the Code of Civil Procedure, including but not limited to Code Civ. Proc. § 410.10 and 42 U.S.C § 1983. III. FACTUAL BACKGROUND ᅠᅠ Upon internal review of the incident, Defendants acknowledge that Officer Shakhzadov's conduct deviated from department policy. Specifically: 1. Plaintiff Montblanc was standing a considerable distance from the tactical scene, not posing an immediate threat or interference with law enforcement activity. 2. Officer Shakhzadov closed distance with Montblanc and deployed a taser unnecessarily, in violation of LSPD's use-of-force escalation guidelines. 3. The incident was not properly recorded or preserved, as no department-authorized scene tape was in place to mark or enforce a perimeter. 4. Shakhzadov proceeded to read Miranda rights to Montblanc without clear custodial interrogation, indicating a lack of legal necessity and training. While Officer Shakhzadov is no longer employed by the Los Santos Police Department, it is the position of the department that had the internal affairs investigations been completed, they would likely have resulted in a sustained policy violation or termination. Accordingly, Defendants are not seeking to shield Officer Shakhzadov's conduct but rather to clarify that the City is not liable under federal constitutional standards or Monell, as outlined bellow. IV. LEGAL ARGUMENTS ᅠᅠ A. The Complaint Fails to Plausibly Allege Municipal Liability Even where individual misconduct is established, municipal liability under Monell v. Dept. of Social Services, 436 U.S 658 (1978), does not attach unless the alleged constitutional violation was the result of official policy, custom, or deliberate indifference. Here, there is no factual allegation of widespread departmental policy encouraging the use of force against non-interfering bystanders. To the contrary, Shakhzadov's actions, as clarified above, were a deviation from LSPD training and procedure. B. The Retaliatory Denial of Plaintiff's Media Card Is Not Causally Connected to a Constitutional Violation Plaintiff also alleges that her application for a Media Card was denied in retaliation for filming the April 18, 2025 incident. However, the denial letter issued by the LSPD's Media Relations Division, signed by Captain Daniel White, clearly indicated that the decision was made following routine evaluation procedures and provides an administrative avenue to appeal, an option Plaintiff declined to pursue. "RE: NEWS MEDIA IDENTIFICATION CARD APPLICATION After careful consideration of your application and review of the relevant criteria set forth by the Media Relations Division, we regret to inform you that your News Media Identification Card application has been denied. ...If you have any questions or require further clarification regarding the outcome of your application, please do not hesitate to contact the Officer-in-Charge, Media Relations Section." This process was neutral, standardized, and applied consistently. It is undisputed that the Plaintiff never appealed the denial or contacted the person in-charge for clarification. Her decision to sue rather than engage the appeals process undercuts any claim that the denial was based on improper motives. The denial off credentials, without more, is insufficient to establish a constitutional claim unless the government action was a. Retaliatory, b. targeted at protected conduct, and c. causally linked to an adverse impact. See Nieves v. Bartless, 139 S. Ct. 1715 (2019). Plaintiff provides no evidence beyond correlation and speculation. She fails to allege that any decision maker was even aware of her pending lawsuit of the denial. Moreover, refusing to issue a media card does not prevent a person from reporting, recording, publishing, or speaking, all of which are the core protections afforded by the First Amendment. The media credential is not a prerequisite for engaging in journalism, it is a facilitative tool for indetification in chaotic or restricted areas, not a constitutional gateway. Plaintiff continued to exercise her right before and after the denial, recording and publishing freely. Plaintiff relies on Sherill v. Knight, 569 F.2d 124 (D.C. Cir. 1977), to support her theory that denial of a media credential constitutes unconstitutional retaliation. But Sherill dealt with credentialing for the White House press room, a government-controlled forum where consistent press access is required to fulfill a federal transparency function. That case has no bearing on local law enforcement. The LSPD is not the White House. The department does not hold official executive briefings, nor does it restrict media access to a select group of individuals. The LSPD's media card system is a basic identification program, designed to help officers recognize legitimate press in fast-moving or dangerous scenes. It is not a system of licensing journalism. Even if Sherill were somehow applicable, Plaintiff received more that the due process outlined in that case, including a written denial and the option to appeal. She failed to exercise those rights. To the extent Plaintiff's complaint arises under 42 U.S.C § 1983, Defendants invoke qualified immunity. There is no clearly established federal law requiring municipal police departments to issue media credentials, nor holding that denial of such credentials, particularly with an appeal process available and unused, constitutes retaliation or prior restraint. Public officials, including those evaluating press applications, are entitled to discretion and legal protection for good-faith administrative decisions. Qualified immunity exists to protect officials from litigation when no clearly established legal duty was violated. Here, the denial was administrative and non-punitive in nature, and did not inhibit Plaintiff's ability to film or report, which she continued to do. This case does not rise to the level of constitutional retaliation. C. Claims Against the Department Must Still Meet Federal Pleading Standards A complaint that merely describes unconstitutional conduct by a single officer, without tying it to a broader departmental failure, does not survive scrutiny. See Ashcroft v. Iqbal, 556 U.S 662 (2009); Bell Atlantic Corp v. Twombly, 550 U.S 554 (2007). Because Officer Shakhzadov acted in clear breach of policy, and because the department did not ratify or authorize his behavior, Plaintiff's § 1983 claim against the Los Santos Police Department fails as a matter of law. D. Individual Liability Remains with the Officer, Not the Department Plaintiff may still pursue claims directly against the now-former officer. However, the City respectfully requests that the claims against it be dismissed with prejudice given the lack of Monell compliance, the lawful and discretionary nature of the credentialing decision, and because Shakhzadov's misconduct, while serious, was not institutionally endorsed. V. CONCLUSION ᅠᅠ Defendants do not dispute that Officer Shakhzadov's conduct may have been improper. However, such conduct does not give rise to liability on the part of the Los Santos Police Department absent a showing of official endorsement, policy, or deliberate indifference. Nor does the denial of Plaintiff's Media Card, absent any substantiated retaliatory policy or plausible factual basis, suffice to establish a viable constitutional claim. Defendants respectfully request that the Court dismiss all claims against the Los Santos Police Department with prejudice and allow Plaintiff to proceed, if at all, solely against the indivdually named officer. DATED: May 02, 2025 By: /s/ Ibraheem A. Davis Ibraheem A. Davis Chief Counsel LOS SANTOS POLICE DEPARTMENT

IN THE SUPERIOR COURT OF THE STATE OF SAN ANDREAS COUNTY OF LOS SANTOS CIVIL DIVISION MONTBLANC, Plaintiff, v. LOS SANTOS POLICE DEPARTMENT, OFFICER AKHMAD SHAKHZADOV (ret.), et al. Defendants. Case No. 25-LSC-04117 ───────────── DEFENDANTS' OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND REQUEST FOR SANCTIONS ───────────── Ibraheem A. Davis, State Bar No. 081000067 [email protected] 1578 Station Ave, 2nd Floor Los Santos, San Andreas 90071 179-9901 Attorney for Defendant LOS SANTOS POLICE DEPARTMENT TABLE OF CONTENTS I. INTRODUCTION............................................................................................................. II. JURISDICTION................................................................................................................ III. FACTUAL BACKGROUND........................................................................................... IV. LEGAL STANDARD....................................................................................................... V. LEGAL ARGUMENT....................................................................................................... A. The IA Records Are Not Discoverable Under Federal Law.................................... B. Plaintiff's Requests are Overbroad and Unduly Burdensome................................. C. Personnel Records and Application Files Implicate Privacy Interests.................... D. No Basis for Sanctions Exists................................................................................. E. Plaintiff's Claims for Punitive Damages is Unsupported........................................ VI. CONCLUSION................................................................................................................. I. INTRODUCTION ᅠᅠ Defendant Los Santos Police Department ("LSPD"), by and through counsel, respectfully submits this Opposition to Plaintiff's Motion to Compel production of certain categories of documents pursuant to Plaintiff's subpoena duces tecum dated April 20, 2025. The Motion is overbroad, procedurally improper, and seeks information that is irrelevant, privileged, and outside the scope of permissible discovery under applicable federal and San Andreas Law. Moreover, Plaintiff seeks sanctions based on an incorrect characterization of Defendants' conduct during discovery. For the reasons detailed herein, the Court should deny the Motion to Compel in its entirety and decline to impose any sanctions on defense counsel. II. JURISDICTION ᅠᅠ This Court has jurisdiction under the San Andreas Constitution and the Code of Civil Procedure, including but not limited to Code Civ. Proc. § 410.10 and 42 U.S.C § 1983. III. FACTUAL BACKGROUND ᅠᅠ This action arises from an alleged incident on April 18, 2025, in which former Officer Shakhzadov, while on duty, allegedly used a taser on Plaintiff Laura Montblanc, who was purportedly recording a police activity from a public space. The Plaintiff claims civil rights violations under 42 U.S.C § 1983 and related causes of action. At the time of the incident, Officer Shakhzadov was employed by the Los Santos Police Department ("LSPD") and was under two pending Internal Affairs ("IA") investigations. On April 28, 2025, Officer Shakhzadov tendered his resignation. In accordance with LSPD internal policy, an officer who resigned while under active IA investigation is automatically designated as "terminated" from service. Both IA cases were administratively closed as a result of his termination. Neither investigation reached a sustained finding, nor did either proceed to adjudication or result in the imposition of discipline. Contrary to Plaintiff's assertions, Defendants have not yet engaged in a meet-and-confer process nor have they produced incident-related materials such as the incident report, or use-of-force documentation. Plaintiff now seeks to compel production of broad categories of unrelated and privileged information without having exhausted proper discovery channels. IV. LEGAL STANDARD ᅠᅠ Under Rule 26(b)(1) of the Federal Rules of Civil Procedure, parties may obtain discovery only of matters that are "relevant to any party's claim or defense and proportional to the needs of the case." Courts are empowered to limit discovery that is unduly burdensome, not reasonably calculated to lead to admissible evidence, or that invades protected privileges. Additionally, under San Andreas law, peace officer personnel records and internal affairs are protected by Pitchess statutes. Disclosure is permitted only when there is a sustained finding of misconduct and when proper procedural requirements have been met. V. LEGAL ARGUMENT ᅠᅠ A. The IA Records Are Not Discoverable Under Federal or State Law Plaintiff demands production of all IA records pertaining to Officer Shakhzadov and others allegedly involved in the denial of a Media Card to Plaintiff. However, these requests must be denied because: 1. The IA investigations concerning Officer Shakhzadov were never concluded and did not result in any sustained findings of misconduct. 2. Officer Shakhzadov is no longer employed by LSPD, and no disciplinary action was adjudicated or enforced besides the termination. 3. Under § 832.7 and SB 1421, only IA records that result in sustained findings of specific types of misconduct (e.g., dishonesty, excessive force causing great bodily injury, sexual assault) are subject to public disclosure. None of these apply here. 4. Additionally, Plaintiff has not filed a proper Pitchess motion, which is the exclusive method for obtaining confidential peace officer personnel records in litigation. Accordingly, any request to produce IA or personnel records is procedurally improper and substantively meritless under both state and federal standards. B. Plaintiff's Requests Are Overbroad and Unduly Burdensome Plaintiff seeks: 1. All SWAT deployments and "newsworthy" incidents from April 18 to present; 2. All Media Card applications and determination; 3. Names of all applicants and their employers; All policies and procedures related to Freedom of the Press. These requests are overbroad, lack temporal and subject-matter specificity, and seek information wholly unrelated to Plaintiff's incident. Courts routinely deny such "fishing expedition" requests, especially when no Monell pattern has been alleged with specificity. See Ashcroft v. Iqbal, 556 U.S 662 (2009). C. Personnel Records and Application Files Implicate Privacy Interests The production of records relating to other individuals' Media Card applications, determinations, and employers raises significant privacy and confidentiality concerns, particularly as these individuals are not parties to this action. Under Gov. § 6254(c) and the San Andreas Constitution's right to privacy, such records may not be disclosed absent a compelling need and protective measures. Defendant's assert that the privacy rights of third parties far outweigh any minimal relevance these requests may hold and request a protective order against their disclosure. D. No Basis for Sanctions Exists While it is accurate that Defendant's have not yet produced incident-related materials or conducted a meet-and-confer, there has been no willful delay, and counsel remains willing to confer with Plaintiff's counsel in good faith regarding discovery scope. Courts will only issue sanctions under Rule 37 when there is clear evidence of bad faith or unjustified resistance to discovery. That threshold is not met here. VI. CONCLUSION ᅠᅠ For the foregoing reasons, Defendants respectfully request that the Court: 1. DENY Plaintiff's Motion to Compel in its entirety; 2. ISSUE A PROTECTIVE ORDER limiting discovery to materials directly related to the April 18, 2025 incident; 3. DECLINE TO ISSUE SANCTIONS against defense counsel; 4. Enforce Pitchess requirements and privacy protections for all IA and personnel materials; and 5. If necessary, permit in camera review of any disputed IA materials prior to any compelled disclosure. DATED: May 01, 2025 By: /s/ Ibraheem A. Davis Ibraheem A. Davis Chief Counsel LOS SANTOS POLICE DEPARTMENT

IN THE SUPERIOR COURT OF THE STATE OF SAN ANDREAS COUNTY OF LOS SANTOS CIVIL DIVISION MICHELLE JEFFERSON, Plaintiff, v. LOS SANTOS POLICE DEPARTMENT, AND OFFICER GREGORY HUNTINGTON Defendants. Case No. 25-LSC-04119 ───────────── DEFENDANT'S ANSWER TO PLAINTIFF'S COMPLAINT ───────────── Ibraheem A. Davis, State Bar No. 081000067 [email protected] 1578 Station Ave, 2nd Floor Los Santos, San Andreas 90071 179-9901 Attorney for Defendant LOS SANTOS POLICE DEPARTMENT TABLE OF CONTENTS I. INTRODUCTION............................................................................................................. II. JURISDICTION................................................................................................................ III. STATEMENT OF THE CASE......................................................................................... IV. STANDARD OF REVIEW............................................................................................... V. LEGAL ARGUMENT....................................................................................................... A. No Constitutional Violation Under First Amendment................... B. Officer's Huntington's Statements Were Reasonable Scene Control Measure........ C. Qualified Immunity Bars Plaintiff's Claim.............................................................. D. No Monell Liability Exists...................................................................................... E. Plaintiff's Claims for Punitive Damages is Unsupported......................................... VI. CONCLUSION.................................................................................................................. I. INTRODUCTION ᅠᅠ Defendant Los Santos Police Department ("LSPD") respectfully submits this Answer to the Complaint filed by Plaintiff Michelle Jefferson. Plaintiff alleges that her constitutional rights were violated during an interaction with Officer Gregory Huntington on April 27, 2025. She claims Officer Huntington unlawfully threatened her with arrest while she was filming a police traffic stop in public. The allegations are without merit. The undisputed facts show that Plaintiff was not arrested, detained, or physically restrained. At all times, Plaintiff remained free to record the incident and did in fact continue filming. The officer's verbal instructions, prompted by Plaintiff's verbal provocation and physical proximity to the officers, were standard lawful crowd control measures issued for scene safety. To the extent that any misunderstanding or overly direct statement were made by Officer Huntington, it should be noted that he is no longer employed by the Los Santos Police Department. He voluntarily resigned from the Department shortly after this incident, and any actions taken were not endorsed by the Department's policies or training. Accordingly, there was no violation of clearly established constitutional rights, no chilling of Plaintiff's speech, and no policy, practice, or deliberate indifference attributable to the LSPD. Plaintiff's claims fail both legally and factually and should be dismissed with prejudice. II. JURISDICTION ᅠᅠ This Court has jurisdiction under the San Andreas Constitution and the Code of Civil Procedure, including but not limited to Code Civ. Proc. § 410.10 and 42 U.S.C § 1983. III. STATEMENT OF THE CASE ᅠᅠ On April 27, 2025, Plaintiff Michelle Jefferson approached Los Santos Police Officer Gregory Huntington during an ongoing traffic stop involving another individual. Plaintiff began filming the police activity from a close distance, which she has a constitutional right to do. However, the interaction escalated when Plaintiff directed verbal insults at the officer, calling him a 'disrespectful punk'. Officer Huntington responded shortly after by saying, 'Okay', and instructing Plaintiff to 'back off', a command consistent with Police Protocols for maintaining scene integrity and officer safety. Plaintiff then asked, 'You got something to say?' to which Officer Huntington replied, 'Seriously', and then, 'I'll arrest you on God'. Plaintiff asserted she was on a public street and continued to provoke the officer, counting down 'Five, Four, Three, Two, One' when warned to step back. Officer Huntington disengaged and walked away after receiving a call on his radio, stating 'You are a lucky woman...or man'. He then ran to his patrol vehicle, likely in response to a higher-priority call. At no point was Plaintiff physically restrained, arrested, or ordered to cease filming. She continued to record and remained at liberty throughout the encounter. Officer Huntington's verbal commands did not result in any physical enforcement or retaliation. His conduct while possible stern in tone, was situational and not a violation of Plaintiff's rights. IV. STANDARD OF REVIEW ᅠᅠ In ruling on a motion to dismiss or for summary judgement in a § 1983 case, the court must determine whether the alleged facts, take in the light most favorable to the plaintiff, establish a constitutional violation. See Saucier v. Katz, 533 U.S. 194 (2001). V. LEGAL ARGUMENT ᅠᅠ A. No Constitutional Violation Under the First Amendment Plaintiff's claim rests on the assertion that her right to record police officers was infringed. The First Amendment does protect the right to record public officials in public spaces. However, this right is no absolute. Courts have held that reasonable restrictions can be imposed to ensure the safety and prevent obstruction. See Gilk v. Cunniffe, 655 F.3d 78, 84 (1st Cir. 2011); Fordyce v. City of Seattle, 55 F.3d 436 (9th Cir. 1995). Here, Plaintiff was never told to stop recording. Instead, she was instructed to move back, a permissible directive to avoid interfering with police duties. The video transcript demonstrated that Plaintiff's ability to record was never restricted. ᅠᅠ B. Officer Huntington's Statements Were Reasonable Scene Control Measures The commands to 'back off' and 'stop interacting with the police' are consistent with law enforcement practices for maintaining control during field operations. In Colten v. Kentucky, 407 U.S 104 (1972), the Supreme Court held that individual do not have an unfettered right to remain at the scene of an arrest if instructed to disperse. Plaintiff's close physical presence and confrontational tone warranted Officer Huntington's response. His remarks were proportionate to the situation and did not exceed constitutional bounds. ᅠᅠ C. Qualified Immunity Bars Plaintiff's Claim Qualified immunity protects government officials performing discretionary functions from civil liability unless they violate clearly established constitutional rights. See Harlow v. Fitzgerald, 457 U.S 800 (1982); Saucier v. Katz, 533 U.S 194 (2001). Even if Officer Huntington's conduct were deemed borderline, the law was not clearly established in April 2025 such that any reasonable officer would know that issuing a verbal warning to a disruptive bystander during a police stop would constitute a First Amendment violation. See Anderson v. Creighton, 483 U.S 635 (1987). ᅠᅠ D. No Monell Liability Exists Under Monell v. Department of Social Services, 436 U.S 658 (1978), municipalities cannot be held liable under § 1983 unless the alleged constitutional violation was caused by policy, custom, or official act. Plaintiff has presented no evidence of any LSPD policy or custom that condones the conduct alleged. On the contrary, Officer Huntington is no longer with the Los Santos Police Department, and his conduct was not ratified by any supervisor or Department policy. There is no factual basis for Monell liability. ᅠᅠ E. Plaintiff's Claim for Punitive Damages is Unsupported Punitive damages are not recoverable against municipalities. See City of Newport v. Fact Concerts, Inc., 453 U.S 247 (1981). Το pursue punitive damages against Officer Huntington in his individual capacity, Plaintiff must prove malicious, wanton, or oppressive conduct. See Smith v. Wade, 461 U.S 30 (1983). Here, no such conduct is present. Officer Huntington issued verbal commands in a tense situation and ultimately disengaged. There was no physical contact, seizure or escalation beyond words. His actions were defensive, not retaliatory. VI. CONCLUSION Plaintiff's Complaint fails to state a claim for which relief can be granted. The record shows no deprivation of constitutional rights. Defendant respectfully requests that the Court dismiss the Complaint with prejudice and grant such other relief as the Court deems just and proper. DATED: May 01, 2025 By: /s/ Ibraheem A. Davis Ibraheem A. Davis Chief Counsel LOS SANTOS POLICE DEPARTMENT

Reddington v. Los Santos Police Department, et al. Case number: 25-LSC-04118 Prepared by: Ibraheem A. Davis DEFENDANTS' MOTION FOR LEAVE TO FILE LATE OPPOSITION _______________________________________________________________________ Defendant, Los Santos Police Department, respectfully move this Court for leave to file their Opposition to Plaintiff's Motion for Summary Judgment. Good cause exists for this request. This motion is filed ensure that the case is decided based on merits rather than a procedural default. I. GOOD CAUSE EXISTS TO GRANT LEAVE The Defendant acknowledges the short lapse in filing its Opposition, which resulted from an excusable forgetfulness, rather than willful neglect. In accord with Pioneer Investment Services Co. v. Brunswick Associates, 507 U.S. 380 (1993), courts recognize that slight errors, if made in good faith, must not deprive a party of an opportunity to be heard. Besides, courts prefer overwhelmingly to decide cases on their merits as to substance rather than procedural niceties (Foman v. Davis, 371 U.S. 178 (1962)). II. PLAINTIFF SUFFERS NO PREJUDICE Plaintiff will not be prejudiced in any significant manner by the temporary delay. As the court held in Bateman v. U.S. Postal Service, 231 F.3d 1220 (9th Cir. 2000), mere delay, standing alone, is insufficient to deny a motion for leave to respond. Granting Defendant leaves to file serves the just disposition of this controversy. In addition to Smith v. City of New York, (S.D.N.Y. Sep. 20, 2021) Plaintiff brought various claims under 42 U.S.C. § 1983 against the City of New York and police officers for excessive force and other deprivations. Both parties moved for summary judgment. The court granted the defendants' motion and dismissed the complaint, emphasizing the importance of proper procedural conduct and timely responses in litigation. III. INTEREST OF JUSTICE DEMANDS THAT THE COURT ALLOW FILING Allowing the Defendant to file its Opposition ensures that the case is decided based on the substantive issues, not a procedural failure. The Court has discretion to grant leave for filing when the delay is minor, and no harm will be caused to the Plaintiff. IV. CONCLUSION For these reasons set forth above, the Defendant respectfully requests that the Court grant leave to file the attached Opposition and allow the matter to proceed on the merits.

Reddington v. Los Santos Police Department, et al. Case number: 25-LSC-04118 Prepared by: Ibraheem A. Davis DEFENSE RESPONSE ON BEHALF OF THE LOS SANTOS POLICE DEPARTMENT _______________________________________________________________________________________ The Los Santos Police Department ("LSPD"), by and through its counsel, respectfully submits this response to the claims raised by the Plaintiff, Marcel Reddington. First and foremost, the Department must clarify that all officers identified in the Plaintiff's filings, specifically Officers Mercer, Ostrenga, and Detective Monaghan, are no longer employed by the Los Santos Police Department as of the date of this filing. Accordingly, the Plaintiff’s attempt to impose liability against the Department under a theory of respondeat superior, or for any ongoing conduct by these individuals, is misplaced. I. Sovereign Immunity Limits Recovery to Statutory Cap While the Plaintiff seeks $10,000,000.00 in damages, such a demand is plainly barred by the San Andreas Sovereign Immunity Act (S.A.S.I.A.), Subsection III. That section expressly states: This statutory cap has been consistently upheld in courts, including Guttenberg v. School Board of Broward County, 303 So. 3d 522 (Fla. 2020) where the court enforced a similar sovereign immunity damages cap despite the claims. Therefore, even assuming liability (which is expressly denied), the Plaintiff’s claim for $10,000,000.00 is legally untenable and must be reduced to the statutory maximum. II. No Monell Liability Without Pattern of Misconduct Plaintiff's complaint implies a broader institutional fault. However, under Monell v. Department of Social Services, 436 U.S. 658 (1978), a government agency cannot be held liable under 42 U.S.C. § 1983 simply because it employs a wrongdoer. There must be proof of a policy or custom that directly caused the alleged injury. No such policy or pattern of unlawful conduct by the LSPD has been pled or established here. An isolated incident, even if proven (which again is expressly denied), does not give rise to Monell liability. See also City of Oklahoma City v. Tuttle, 471 U.S. 808 (1985). III. Qualified Immunity Bars Recovery Against Individual Officers Furthermore, assuming arguendo that any of the named officers were still employed, each would be entitled to qualified immunity. Under Pearson v. Callahan, 555 U.S. 223 (2009), government officials performing discretionary functions are immune from civil damages unless they violate "clearly established" constitutional rights. Given the circumstances described, wherein the officers reportedly believed an armed threat existed, their actions fall within the zone of protection afforded by qualified immunity. IV. Conclusion While the Plaintiff’s injuries are not minimized, the LSPD respectfully submits that: - The claims against the Department fail as a matter of law; - The $10,000,000.00 demand exceeds the legal limit of the Sovereign Immunity Act, sub-section (C) of section three. Exceptions to Sovereign Immunity. - No Monell liability is established; - Qualified immunity would independently bar any personal recovery against the named officers. - Plaintiff is to submit a medical record of constituted injuries, given consideration to the claimant's past filed lawsuits against the department, presumably proposing a bad intent in defaming the LSPD. Accordingly, the Department respectfully requests that this Court dismiss the Plaintiff’s complaint with prejudice, or, in the alternative, substantially limit any recovery consistent with applicable law.

Alan Saucedo v. An Unknown Los Santos Police Department (LSPD) Police Officer, The Staff Officers of the LSPD. Case number: 25-LSC-04116 Prepared by: Ibraheem A. Davis DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION TO DENY DEFENDANT'S MOTION AND CENSURE THE DEFENDANT FOR THE USE OF AI TOOLS _____________________________________________________________________________________________________________________________________________________________________ COMES NOW, Ibraheem Davis, legal representative for the Los Santos Police Department (LSPD), and respectfully submits this response to Plaintiff's opposition to Defendant's Motion of Stay of Proceedings. I. Introduction Plaintiff's counsel has made several unfounded accusations that warrant immediate address. Most egregiously, counsel alleges that I have utilized artificial intelligence to draft my motions and has declared, without substantive evidence, that the "91 percent" of my filing is "AI Generated" based solely on a proprietary algorithm with known reliability issues. This allegation is both factually wrong and legally irrelevant to the merits of LSPD's motion. II. Response to Allegations 1. The AI Detection Claim is Unreliable and Legally Irrelevant Plaintiff's counsel relies on "Quillbot", a text analysis tool with documented limitations. Courts have consistently recognized that such AI detection tools produce unreliable results with false positive rates exceeding 25% in peer-reviewed studied. Even one of the most if not popular AI Detection tools "Turnitin" claimed themselves that their product produce false positives. The San Andreas Bar Association has not established any prohibition against drafting assistance tools, which many attorneys utilize for formatting, citation checking and language refinement; Practices equivalent to traditional tools like spelling and grammar checkers. As held in Pirelli Armstrong Tire Corp v. Raines, "Courts have never required attorneys to compose all materials from scratch" The typing errors noted by the opposing counsel (Duplicate Roman Numbers) actually contradict their allegation of AI usage, as such errors are characteristic of human drafting. These minor typographical errors in no way diminish the substantive legal arguments presented on behalf of the LSPD. In Hamer v. Neighborhood Housing Servs. of Chicago, the Court held that "procedural rules should not be applied in a way that created meaningless procedural traps". 2. The UK Citation is Both Relevant and Appropriate Plaintiff's objection to my citation of a House of Lords decision demonstrates a serious misunderstanding of comparative law principles. While not binding, persuasive authority from respected common law jurisdictions in routinely cited in complex procedural matters where San Andreas precedent is developing. In American Bank & Trust Co. v. Federal Reserve Bank, where Justice Holmes noted that "the Court may appropriately look to decisions of English courts for persuasive value in interpreting common law principles". III. Defense Against Plaintiff's Claim of Untimeliness Defendant acknowledges that the motion in question was filed after the court-imposed deadline for responses. However, Defendant respectfully submits that the delay was caused by reasonable circumstance and show not result in a dismissal of the motion. More specifically: Good Cause for Delay: The delay in filling was due to extenuating circumstances, including an unavoidable personal matter that temporarily impacted the preparation and filing of the motion. Defendant, through counsel, takes full responsibility for this oversight but emphasizes that the delay did not prejudice the Plaintiff or harm the integrity of the judicial process. As such, Defendant respectfully requests that the Court exercise its discretion and allow the motion to proceed on the merits No Prejudice to Plaintiff The Plaintiff has not shown, and cannot show, any material prejudice caused by the delay. The issues raised in the motion remain relevant, and there is no indication that the delay has affected the Plaintiff's ability to respond or prepare for trial. Denying the motion on procedural grounds alone would serve no legitimate purpose and would frustrate the interests of justice. Substantial Compliance Defendant has made substantial compliance with the requirements set forth by the court, and any minor delay should be excused in light of the circumstances, particularly when no harm has been done to the Plaintiff's case. IV. Conclusion I respectfully request that this Court: Disregard plaintiff's unfounded allegations regarding drafting methods; Consider the substantive merits of the stay request as outlined in our original motion; Admonish plaintiff's counsel for engaging in personal attacks rather than addressing legal substance; and Grant the requested stay of proceedings for the reasons outlined in our initial filing. Respectfully submitted, /s/ IBRAHEEM A, DAVIS Ibraheem A. Davis Legal Representative Los Santos Police Department

Montblanc v. Shakhzadov, Los Santos Police Department, et al. Case number: 25-LSC-04117 Prepared by: Ibraheem A. Davis DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION TO DENY DEFENDANT'S MOTION AND CENSURE THE DEFENDANT FOR THE USE OF AI TOOLS _____________________________________________________________________________________________________________________________________________________________________ COMES NOW, Ibraheem Davis, legal representative for the Los Santos Police Department (LSPD), and respectfully submits this response to Plaintiff's opposition to Defendant's Motion of Stay of Proceedings. I. Introduction Plaintiff's counsel has made several unfounded accusations that warrant immediate address. Most egregiously, counsel alleges that I have utilized artificial intelligence to draft my motions and has declared, without substantive evidence, that the "91 percent" of my filing is "AI Generated" based solely on a proprietary algorithm with known reliability issues. This allegation is both factually wrong and legally irrelevant to the merits of LSPD's motion. II. Response to Allegations 1. The AI Detection Claim is Unreliable and Legally Irrelevant Plaintiff's counsel relies on "Quillbot", a text analysis tool with documented limitations. Courts have consistently recognized that such AI detection tools produce unreliable results with false positive rates exceeding 25% in peer-reviewed studied. Even one of the most if not popular AI Detection tools "Turnitin" claimed themselves that their product produce false positives. The San Andreas Bar Association has not established any prohibition against drafting assistance tools, which many attorneys utilize for formatting, citation checking and language refinement; Practices equivalent to traditional tools like spelling and grammar checkers. As held in Pirelli Armstrong Tire Corp v. Raines, "Courts have never required attorneys to compose all materials from scratch" The typing errors noted by the opposing counsel (Duplicate Roman Numbers) actually contradict their allegation of AI usage, as such errors are characteristic of human drafting. These minor typographical errors in no way diminish the substantive legal arguments presented on behalf of the LSPD. In Hamer v. Neighborhood Housing Servs. of Chicago, the Court held that "procedural rules should not be applied in a way that created meaningless procedural traps". 2. The UK Citation is Both Relevant and Appropriate Plaintiff's objection to my citation of a House of Lords decision demonstrates a serious misunderstanding of comparative law principles. While not binding, persuasive authority from respected common law jurisdictions in routinely cited in complex procedural matters where San Andreas precedent is developing. In American Bank & Trust Co. v. Federal Reserve Bank, where Justice Holmes noted that "the Court may appropriately look to decisions of English courts for persuasive value in interpreting common law principles". III. Defense Against Plaintiff's Claim of Untimeliness Defendant acknowledges that the motion in question was filed after the court-imposed deadline for responses. However, Defendant respectfully submits that the delay was caused by reasonable circumstance and show not result in a dismissal of the motion. More specifically: Good Cause for Delay: The delay in filling was due to extenuating circumstances, including an unavoidable personal matter that temporarily impacted the preparation and filing of the motion. Defendant, through counsel, takes full responsibility for this oversight but emphasizes that the delay did not prejudice the Plaintiff or harm the integrity of the judicial process. As such, Defendant respectfully requests that the Court exercise its discretion and allow the motion to proceed on the merits No Prejudice to Plaintiff The Plaintiff has not shown, and cannot show, any material prejudice caused by the delay. The issues raised in the motion remain relevant, and there is no indication that the delay has affected the Plaintiff's ability to respond or prepare for trial. Denying the motion on procedural grounds alone would serve no legitimate purpose and would frustrate the interests of justice. Substantial Compliance Defendant has made substantial compliance with the requirements set forth by the court, and any minor delay should be excused in light of the circumstances, particularly when no harm has been done to the Plaintiff's case. IV. Conclusion I respectfully request that this Court: Disregard plaintiff's unfounded allegations regarding drafting methods; Consider the substantive merits of the stay request as outlined in our original motion; Admonish plaintiff's counsel for engaging in personal attacks rather than addressing legal substance; and Grant the requested stay of proceedings for the reasons outlined in our initial filing. Respectfully submitted, /s/ IBRAHEEM A, DAVIS Ibraheem A. Davis Legal Representative Los Santos Police Department

Alan Saucedo v. An Unknown Los Santos Police Department (LSPD) Police Officer, The Staff Officers of the LSPD. Case number: 25-LSC-04116 Prepared by: Ibraheem A. Davis DEFENDANT's MOTION TO STAY PROCEEDINGS PENDING INTERNAL AFFAIRS INVESTIGATION _____________________________________________________________________________________________________________ Defendant respectfully requests a temporary stay of proceedings in the above-captioned matter, pending the completion of the ongoing Internal Affairs investigation related to the conduct of the LSPD Officer. This motion is not intended to delay proceedings unduly, but rather to ensure the Court is presented with the most complete and accurate factual record possible. The outcome of said investigation bears directly upon material issues in dispute. I. Judicial Economy and Efficiency Courts have long recognized the authority to stay civil proceedings when doing so would serve judicial economy, conserve resources, or avoid conflicting outcomes. In Landis v. North American Co., 299 U.S. 248 (1936), the U.S. Supreme Court affirmed that "n the exercise of its sound discretion, a court may hold one lawsuit in abeyance to abide the outcome of another which may substantially affect it or be dispositive of the issues." II. Importance of Internal Investigative Findings in Law Enforcement Cases In Allen v. City of Oakland (N.D. Cal.), the court underscored the critical role of internal police investigations when systemic misconduct was alleged. The resulting reforms and oversight shaped the resolution of civil claims, demonstrating that deferring litigation to await investigatory findings may enhance both accuracy and fairness. Similarly, in O'Brien v. Chief Constable of South Wales Police ([2005] UKHL 26), the House of Lords acknowledged the probative value of internal disciplinary findings in civil claims concerning police conduct. The judgment highlighted that internal reviews often yield essential context and factual clarification relevant to civil proceedings III. Protection of Due Process and Officer's Rights Premature disclosure of the identity of the Unknown Officer, prior to the conclusion of the Internal Affairs investigation, would risk violating the officer's due process rights. Officers, subject to administrative or disciplinary review are entitled to a full and fair internal process, free from premature public exposure or legal assumption of guilt. Revealing the officer's identity at this stage may also: Undermine the integrity of impartiality of the Internal Affairs investigation; Compromise the safety and privacy of the officer and others involved; Diminish the Department's ability to conduct effective and unbiased internal oversight; Violate any existing protective policies regarding officers under investigation. This request is therefore not only consistent with legal precedent but also a necessary safeguard for constitutional and procedural fairness. III. Risk of Premature or Fragmented Litigation Absent a stay, the parties risk engaging in premature motion practice and discovery based on incomplete or evolving factual circumstances. This may result in the need for amendments, redundant motions, or the revisiting of rulings, all of which impose additional burdens on the Court and litigants. IV. Good Faith Request Defendant emphasizes that this request is made in good faith and is narrowly tailored. The requested stay is limited in scope and duration, only until the Internal Affairs Group concludes its review. The intent is not to delay this litigation indefinitely, but to ensure adjudication proceeds on a full and reliable evidentiary foundation. V. Conclusion WHEREFORE, Defendant respectfully prays that the Court: GRANT a temporary stay of proceedings pending the conclusion of the Internal Affairs investigation; SET a status review date within a reasonable timeframe to evaluate the investigation’s progress and reassess the stay’s necessity; RETAIN full discretion to lift or modify the stay as appropriate. Respectfully submitted, /s/ IBRAHEEM A, DAVIS Ibraheem A. Davis Legal Representative Los Santos Police Department

Montblanc v. Shakhzadov, Los Santos Police Department, et al. Case number: 25-LSC-04117 Prepared by: Ibraheem A. Davis DEFENDANT's MOTION TO STAY PROCEEDINGS PENDING INTERNAL AFFAIRS INVESTIGATION _____________________________________________________________________________________________________________ Defendant respectfully requests a temporary stay of proceedings in the above-captioned matter, pending the completion of the ongoing Internal Affairs investigation related to the conduct of Officer Akhmad. This motion is not intended to delay proceedings unduly, but rather to ensure the Court is presented with the most complete and accurate factual record possible. The outcome of said investigation bears directly upon material issues in dispute. I. Judicial Economy and Efficiency Courts have long recognized the authority to stay civil proceedings when doing so would serve judicial economy, conserve resources, or avoid conflicting outcomes. In Landis v. North American Co., 299 U.S. 248 (1936), the U.S. Supreme Court affirmed that "n the exercise of its sound discretion, a court may hold one lawsuit in abeyance to abide the outcome of another which may substantially affect it or be dispositive of the issues." II. Importance of Internal Investigative Findings in Law Enforcement Cases In Allen v. City of Oakland (N.D. Cal.), the court underscored the critical role of internal police investigations when systemic misconduct was alleged. The resulting reforms and oversight shaped the resolution of civil claims, demonstrating that deferring litigation to await investigatory findings may enhance both accuracy and fairness. Similarly, in O'Brien v. Chief Constable of South Wales Police ([2005] UKHL 26), the House of Lords acknowledged the probative value of internal disciplinary findings in civil claims concerning police conduct. The judgment highlighted that internal reviews often yield essential context and factual clarification relevant to civil proceedings III. Risk of Premature or Fragmented Litigation Absent a stay, the parties risk engaging in premature motion practice and discovery based on incomplete or evolving factual circumstances. This may result in the need for amendments, redundant motions, or the revisiting of rulings, all of which impose additional burdens on the Court and litigants. IV. Good Faith Request Defendant emphasizes that this request is made in good faith and is narrowly tailored. The requested stay is limited in scope and duration, only until the Internal Affairs Group concludes its review. The intent is not to delay this litigation indefinitely, but to ensure adjudication proceeds on a full and reliable evidentiary foundation. V. Conclusion WHEREFORE, Defendant respectfully prays that the Court: GRANT a temporary stay of proceedings pending the conclusion of the Internal Affairs investigation; SET a status review date to evaluate the investigation’s progress and reassess the stay’s necessity; RETAIN full discretion to lift or modify the stay as appropriate. Respectfully submitted, /s/ IBRAHEEM A, DAVIS Ibraheem A. Davis Legal Representative Los Santos Police Department

Montblanc v. Los Santos Police Department Police Officer Shakhzadov (61658), and the Los Santos Police Department Case Number: 25-LSC-04113 Prepared by: Ibraheem A. Davis DEFENDANTS’ MOTION FOR EXTENSION OF TIME TO FILE RESPONSE, SUPPLEMENT IMMUNITY DEFENSE, AND COMPLY WITH SUBPOENA _______________________________________________ The Defendant, Los Santos Police Department, by and through undersigned counsel, and respectfully move this Honorable Court to grant an additional 72 hours to: Supplement the sovereign immunity pleading as directed by the Court, and To produce responsive documents as outlined in the Court’s Subpoena Duces Tecum. In support of this Motion, the Defendant state the following: The Court has granted Defendants 48 hours to supplement the immunity defense; however, additional time is necessary to review applicable precedents cited by the Plaintiff and provide a more detailed brief. The production of documents in response to the Subpoena requires coordination with internal records personnel, and proper redaction of sensitive information in accordance with Department and legal standards. This is the Defendants’ first request for an extension and is made in good faith, not for the purpose of delay. No prejudice will result to the Plaintiff, and the extension will promote a more complete and just record before the Court. WHEREFORE, Defendants respectfully request that the Court grant a 72 hour extension, extending the current deadline to 23 April 2025, for the supplementation of the sovereign immunity defense and compliance with the Subpoena Duces Tecum. Respectfully submitted, /s/ IBRAHEEM A, DAVIS Ibraheem A. Davis Legal Representative Los Santos Police Department

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