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4 <br />3. This Complaint is brought pursuant to Sections 603-21.5(3), 634-35, and 663-1 of <br />the Hawaii Revised Statutes (hereinafter referred to as "HRS"). <br />4. Venue is proper in this Court under Section 603-36 of the HRS, as the alleged <br />events arose from actions between Plaintiff and Defendants, and events and/or omissions giving <br />rise to this action arose in this judicial circuit. <br />5. Personal jurisdiction is proper in this Court because all of the above -named <br />Defendants have minimum contacts with the State of Hawaii because all of the Defendants are <br />employed by the State of Hawaii, and as such have direct contact with the State of Hawaii. <br />6. All of the Defendants and Plaintiff are residents of Hawaii. <br />7. On June 12, 2024, Hawaii Civil Rights Commission has issued a "Notice of <br />Dismissal and Right to Sue in David J. Freedman vs. County of Hawaii, FEPA No. 22893; <br />EEOC No. 486-2024-00383" ,for Plaintiff's sex discrimination allegations 1, giving the <br />Plaintiff a right to file a private lawsuit against the above listed Defendants in the State Circuit <br />Court within ninety (90) days after receipt of the above referenced June 12, 2024 Notice of Right <br />to Sue pursuant to Hawaii Revised Statutes Section. 368-12 and H.A.R. §12-46-20. <br />M. FACTS <br />8. Plaintiff reiterates and incorporates by reference the preceding paragraphs of this <br />Complaint as though set forth fully herein. <br />9. Plaintiff graduated from the University of Southern California in 2010 with a <br />master's degree in film and TV Production. <br />1 When Complaint was originally filed — Dkt. 1, Plaintiff was also issued prior to that Right to <br />Sue Letter for his Age Discrimination claim <br />-4- <br />EXHIBIT "A" Pg4 <br />Page 4 of 25 <br />