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11 <br />63. On June 2, 2022, Plaintiff learned that the new film commissioner had been selected <br />via an announcement that ran in the Hawaii Herald Tribune. <br />64. The new film commissioner to be selected was Aulani Freitas ("Freitas"), someone <br />"decades younger than Plaintiff with far less entertainment industry experience and connections <br />than Plaintiff'— both of which are key to the success of bringing productions to the Big Island. <br />65. Based on his experience and resume, Plaintiff was exceptionally qualified for the <br />position due to his skill set and possession of many years of work -related experience. <br />66. Upon information and belief, this position is within the County of Hawai'i's <br />Department of Research and Development ("R&D"). <br />67. Upon information and belief, the Department of Human Resources ("HR"), <br />oversees and administers the recruitment program for the County of Hawai' i, assisting departments <br />in the filing of civil service positions. <br />68. Plaintiff is decades older than Freitas and a gay male, with many more years of <br />professional experience related to the requirements of the position. <br />3 <br />69. Plaintiff was informed on multiple occasions and led to believe that the open <br />position was located in Hilo, Hawaii and that he was an impressive candidate. <br />70. When Plaintiff spoke to Mayor Mitch Roth about the position, who even <br />recommended that Plaintiff apply for the position, Plaintiff asked where the film commissioner's <br />office was located and was informed that the location of the office was in Hilo. <br />71. Plaintiff also informally chatted with Mr. Adams, the hiring manager, who also <br />confirmed that the office was located in Hilo. <br />72. Plaintiff also did his own research before starting his application by visiting the Big <br />Island Film Office Website: https•//www.hawaiiislandfilm.com/contact/. <br />-11- <br />EXHIBIT "A" <br />Page 11 of 25 <br />Pgl 1 <br />