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10 <br />54. Plaintiff, an openly and obvious older gay male had no chance despite his <br />impressive qualifications. <br />55. On March 7, 2022, Mr. Adams informed Plaintiff via blind copy email that the <br />position had "opened" and was now publicly posted but Adams never had any intention on even <br />interviewing the Plaintiff because Plaintiff was an older gay male, and NOT a young attractive <br />female. <br />56. Upon reviewing the post, Plaintiff noted that the application window was for a very <br />small window of only nine days. <br />57. Plaintiff checked the county website and confirmed that the physical office location <br />for the film commissioner was located in Hilo, Hawaii. <br />58. Accordingly, Plaintiff applied for the position of Economic Development Specialist <br />III SR-24 and listed Hilo as Plaintiff's location. <br />59. On April 11, 2022, Plaintiff received a confirmation email from Defendant that <br />Plaintiff received a rating of 70 and was eligible for hire to the position. <br />60. Other than an automated confirmation that Plaintiff's application had been <br />submitted, Plaintiff did not receive any further communication or feedback from the County of <br />Hawaii with respect to his application. <br />61. Upon information and belief, Adams purpose decided to ignore Plaintiff's <br />application and not even consider him for a position because Adams wanted to hire young <br />attractive females ONLY. <br />62. Defendant County of Hawaii admits that in May 2022, Mr. Douglas Adams, <br />Director of the Department of Research and Development received an inquiry from Claimant <br />regarding his application. <br />-10- <br />EXHIBIT "A" Pg10 <br />Page 10 of 25 <br />