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13 <br />82. Defendant contends that "despite Mr. Freedman's beliefs, Claimant's application <br />was not referred to R&D for consideration because the position of Economic Development <br />Specialist III SR 24 was for an immediate full-time vacancy in Kailua-Kona" and that "within the <br />application's agency -wide questions, Claimant expressly indicated that he was available for a <br />position only in the Hilo District." <br />83. Notably, Freitas lives in Kamuela, Hawaii where there are no county offices. <br />During his deposition, Adams admitted that Freitas did not even work in Kona when she was hired <br />as a film commissioner but rather at different locations. <br />84. Kona location was a lie and an excuse by Adams to hide the fact he was only hiring <br />young attractive females of color for the film commissioner position. <br />85. Despite his impressive qualifications and his application, Plaintiff was NOT even <br />interviewed. <br />86. Upon information and belief, Mr. Adams, targeted another young attractive female <br />of color in Freitas to hire her into a permanent film commissioner position and he did hire her. <br />87. Adams admitted under oath during his deposition that Freitas was sexually <br />attractive. <br />88. In fact, by the time Freitas was hired and since retirement of previous <br />permanent film commissioner in June 2021, Adams has already personally promoted 2 other <br />young attractive unqualified females of color into a temporary position of the film <br />commissioner position even though he knew all along of Plaintiff and his interest and his <br />impressive qualifications. <br />89. Adams also admitted under oath that the other 2 young females he promoted <br />into film commissioner position were also attractive. <br />-13- <br />EXHIBIT "A" Pg13 <br />Page 13 of 25 <br />