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y IL <br />Kahihikolo Defendants Gaspar and Taniyama observed Kainoa in a Vehicle with Jacqueline <br />Keanaaina ("Keanaaina"), and pursued that Vehicle which eventually came to a stop. <br />14. Plaintiffs are informed and believe, and thereupon allege, that when the Vehicle <br />stopped, Keanaaina got out and attempted to flee while Kainoa remained seated in the Vehicle. <br />15. Plaintiffs are informed and believe, and thereupon allege, that although Kainoa did <br />not attempt to flee and posed no threat to the officers, Defendants Gaspar and Taniyama immediately <br />fired several shots into the Vehicle striking and killing Kainoa. <br />16. Plaintiffs are informed and believe, and thereupon allege, that Defendants Gaspar and <br />Taniyama violated HPD policies pertaining to the standards for use of forces when they discharged <br />their firearms thereby directly, proximately, and foreseeably causing the death of Kainoa as alleged <br />herein. <br />17. Since Kainoa's death Defendants Gaspar, Taniyama, and certain of the Doe <br />Defendants have harassed Plaintiffs' family members and repeatedly have made false, misleading, <br />and/or threatening statements about the relevant events to support the narrative that the shooting of <br />Kainoa was justified. <br />18. Plaintiffs are informed. and believe, and thereupon allege, that Defendants Gaspar and <br />Taniyama violated HPD policies and applicable national use of force standards when they resorted to <br />deadly force without justification and without employing any conflict de-escalation or intervention <br />techniques. <br />19. Plaintiffs are informed and believe, and thereupon allege, that Defendants Gaspar and <br />Taniyama were not provided with adequate training in conflict de-escalation tactics. <br />20. Plaintiffs are informed and believe, and thereupon allege, that Defendants Gaspar <br />and Taniyama were not provided with adequate training in apprehending a suspect in a vehicle. <br />0 <br />re. <br />