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2 Hawaii. Plaintiff was born in 1961. 2. Defendant COUNTY OF HAWAII, STATE OF HAWAII (hereinafter "HAWAII I COUNTY"), at all relevant times mentioned in this Complaint, is a municipal corporation, with primary offices located in Hilo, Hawaii, organized under the laws of the State of Hawaii, and was at all times relevant herein, liable for the acts and/or omissions of the Hawaii County Department of Research and Development ("R&D"), the Department of Human Resources ("HR"), and its administrators and employees. 3. Defendant DOUGLASS S. ADAMS ("Adams"), at all relevant times mentioned in this Complaint, was a resident of the County of Hawaii, State of Hawaii. Adams was at relevant times a director for the Hawaii County Department of Research and Development ("R&D"). Under his watch, he essentially solely controlled hiring for the Film Commissioner position withing the R&D. 4. Adams is being sued in his individual capacity for aiding and abetting discrimination of Plaintiff under the Lales v. Wholesale Motors Co., 328 P.3d 341, 356 (Haw. 2014) doctrine that stated following: "In contrast, at the same time the legislature made it unlawful for employers to harass or retaliate against any individual, the legislature explicitly stated that it was unlawful for "any person whether an employer, employee or not, to aid, abet, incite, compel or coerce the doing of any of the practices forbidden by the Act, or to attempt to do so." 1963 Haw. Sess. Laws Act 180, § 1 at 224 (emphasis added) (predecessor to HRS § 378- 2(3)). In other words, the legislature plainly understood how to proscribe the conduct of individual employees, and when it intended to do so, it did so explicitly and unequivocally. (Emphasis added). 5. Defendants DOE. PERSONS 1-10, DOE CORPORATIONS I-10, DOE PARTNERSHIPS 1-10, ROE "NON-PROFIT" CORPORATIONS 1-10, DOE UNINCORPORATED ORGANIZATIONS 1-10 and ROE GOVERNMENTAL ENTITIES -2- EXHIBIT "A" Pg2 Page 2 of 25