UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

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1 Case :-cv-0-sjo-rao Document Filed // Page of Page ID #: 0 0 HANSON BRIDGETT LLP KURT A. FRANKLIN, SBN kfranklin@hansonbridgett.com SAMANTHA WOLFF, SBN 00 swolff@hansonbridgett.com JENNIFER ANIKO FOLDVARY, SBN jfoldvary@hansonbridgett.com Market Street, th Floor San Francisco, California 0 Telephone: () -00 Facsimile: () - HANSON BRIDGETT LLP TYSON M. SHOWER, SBN 0 tshower@hansonbridgett.com LANDON D. BAILEY, SBN 0 lbailey@hansonbridgett.com 00 Capitol Mall, Suite 00 Sacramento, California Telephone: () - Facsimile: () - OTTEN LAW, PC VICTOR OTTEN, SBN 00 vic@ottenlawpc.com KAVITA TEKCHANDANI, SBN kavita@ottenlawpc.com 0 Pacific Coast Highway, #00 Torrance, California 00 Telephone: (0) - Facsimile: (0) - Attorneys for Plaintiffs CORY SPENCER, DIANA MILENA REED, and COASTAL PROTECTION RANGERS, INC. UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION CORY SPENCER, an individual; DIANA MILENA REED, an individual; and COASTAL PROTECTION RANGERS, INC., a California non-profit public benefit corporation, Plaintiffs, CASE NO. :-cv-0-sjo (RAOx) DECLARATION OF JOSEPH LANNING IN SUPPORT OF PLAINTIFFS' MOTION FOR CLASS Judge: Hon. S. James Otero Date: February, 0 Time: 0:00 a.m. Crtrm.: 0C. -- :-cv-0-sjo (RAOx) DECLARATION OF JOSEPH LANNING IN SUPPORT OF PLAINTIFFS' MOTION FOR CLASS

2 Case :-cv-0-sjo-rao Document Filed // Page of Page ID #: 0 0 v. LUNADA BAY BOYS; THE INDIVIDUAL MEMBERS OF THE LUNADA BAY BOYS, including but not limited to SANG LEE, BRANT BLAKEMAN, ALAN JOHNSTON AKA JALIAN JOHNSTON, MICHAEL RAE PAPAYANS, ANGELO FERRARA, FRANK FERRARA, CHARLIE FERRARA, and N. F.; CITY OF PALOS VERDES ESTATES; CHIEF OF POLICE JEFF KEPLEY, in his representative capacity; and DOES -0, Defendants. I, Joseph Lanning, declare as follows:. For the last 0 years, I have resided in San Pedro, California. Currently, I am a retired art director. I have personal knowledge of the matters stated in this declaration and, if called as a witness, could and would testify competently as to its contents.. I grew up in Manhattan Beach, California, and I attended Aviation High School in Redondo Beach, California. I have also lived in Torrance, Lawndale, and Redondo Beach, all in California. I attended El Camino College in Torrance where I received an associate s degree in general education.. I enjoy hiking and walking my dogs, both German shepherds, and I like having the freedom to hike and walk my dogs wherever I can. I have driven by Lunada Bay, and it s a beautiful place where I would like to hike or walk my dogs.. -- :-cv-0-sjo (RAOx) DECLARATION OF JOSEPH LANNING IN SUPPORT OF PLAINTIFFS' MOTION FOR CLASS

3 Case :-cv-0-sjo-rao Document Filed // Page of Page ID #: 0 0. However, for more than 0 years, while living in the South Bay area, I have heard that Lunada Bay is off-limits to outsiders and that people will be bullied and assaulted and their cars will be vandalized if they go there. Although my German shepherd dogs might protect me, I would be concerned that they would harm someone harassing me and I would be held liable. I am informed and believe that the locals at Lunada Bay will harass not just surfers but anyone who might be perceived as encroaching on their territory. For these reasons, I have avoided visiting Lunada Bay.. On January 0, 0, I wrote an to Palos Verdes Estates Police Chief Jeff Kepley about my concerns regarding the bullying and illegal activities of the Lunada Bay Boys. Chief Kepley responded on the same day, and said that City staff is considering options to deal with this situation including gang-related legal remedies.... Work continues on that front. Further, staff is assessing options related to the stone patio, which too is not as simple as one would think. Attached as Exhibit is a true and correct copy of this exchange.. If it were safe for me to visit Lunada Bay and I were not hassled, I would like to visit Lunada Bay to hike or walk my dogs. However, because of the actions by the Lunada Bay Boys and the City of Palos Verdes Estates, I am denied access to Lunada Bay.. I want the aggressive Bay Boys that engage in unlawful activity to be barred from using this beach for sufficient time to change attitudes and for this beach to be returned to the public. I want the City of Palos Verdes Estates to enforce its ordinances fairly, for it to provide signage so people will know Lunada Bay is a public beach, for it to provide signage marking the safest trails to the shoreline, and for the police to take complaints by visiting beachgoers seriously and be available to help in case non-local beachgoers are assaulted or otherwise unlawfully excluded from Lunada Bay. I want to. -- :-cv-0-sjo (RAOx) DECLARATION OF JOSEPH LANNING IN SUPPORT OF PLAINTIFFS' MOTION FOR CLASS

4 Case :-cv-0-sjo-rao Document Filed // Page of Page ID #: be able to visit Palos Verdes Estates beaches, specifically Lunada Bay, without being intimidated and to be safe in my person and property. And if am harassed, I want the City of Palos Verdes Estates police to take my complaints seriously, instead of simply telling me to get along with the locals. declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed in ~~`~ ~'~b,california on December ~, 0. 0 JOSEPH CANNING. "I Q -- :-cv-0-sjo (RAOx) DECLARATION OF JOSEPH LANNINO IN SUPPORT OF PLAfNTIFFS' MOTION FOR CLASS

5 Case :-cv-0-sjo-rao Document Filed // Page of Page ID #: EXHIBIT

6 Case :-cv-0-sjo-rao Document Filed // Page of Page ID #: about,blank Print -Close ~,t~'iriclo~~~ - Cick bare at tkte ~ot#ozn of the to print single message Subject: Re: Bay Boys Solution From: Jeff Kepley (jkepfey c~pvestates,org) 'Ta: jplanningqyahoo,com; Cc: jgaaihart a~pvesrates,org; jking@pvestates.org; bpeterson@pues~at~es.arg; jrea@pvestates.org; jvndever a~pveseates,ort~; Date: Saturday, January ~Q, 0~G ~;A PPA Tli~uak }you far your and suggestion ~Ir, Landitx~. Our City staff tnemt~ers are corasitlerizag many options to deal ~~~i#~i this situation incluclin.~ fi g-related legal rernedie~. You n~~y l:no~~~, ki0~'zv~!" ~El~.IJLICtf'! cpp~' to only mezi~bers of the suuject group. Thz issue rez~aisas, far enfarcezxxent azicl ~rosecu#ion purposes, ~t~~ia is and is nvt a z~~ember o t~iat group. ~~~ ork ca~.tin.ues a~n tkiat front, F~irther, tc~f S c~f~a o~tians related to tlae s#ozie patio, t~~hic}~ too is not as simple as oz~e t~~atild thii~c. I so appreciate your set~tiznents and t ie~~~s, '~Fe are cannt~~iztecl to crew#iz~g axed main#a niz~g access to our coastal «paters for all to ~~njay Fu~,d znc~ tk~e lzgac}~ a xhe Bay $ay~s. Z~'z r~z~cl and ap~reciat~ your support, Jeff I{epley P'E Polio Chizf Jeff ~~pler~ Ott Jati 0, 0, at := ANI, Joe Lannis~g <j~lanninc c?~,~a~aoo.cc~m~ t~~rote: Dear Chief Keply, Hatire you considered filing a gang injunction against these overage surf punk #hugs? if they ~;rere forbidden access to the oceanfront area they have ruled aver in defiance of the law for the past 0+years, problem sowed. Surely you know wlio they all are and can readily demonstrate to a judge that their pa~t behavior warrants #heir permanent expulsion from Canada bay and i~' llvirotls, Also, demolishing their "fart"' +mould be a goad start, considering it is a tangible symbol of their poti~~er, Ids remqual, as well as an injunction, ~.vauld send a strong message to the community end the world that the days of Bey Boy hegemony ~a~ill nq longer be tolerated or condoned by PVE. These actions would go along way #o repairing tl~e famished and embarrassing perception of PVE as accepting of uiolent localism, As it stands now. adjacent communities and the press, locally, ntionally, and internationally, consider P~.~E a haven for illegal and violent behavior, as long as it is committed by locals. The Ba}~ Bflys have "o~.~med" that piece f ace~nfront for ~~ years; it is considerably past time for the rest of us to have free and safe access to this section of the public coast, Sincerely, Joe Canning Stn Peciro