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29. On January 10, 2022, Plaintiff again emailed Mr. Adams, stating that it had been <br />six months and the job was still not posted. <br />30. Mr. Adams replied to Plaintiff, stating that the job would be posted. <br />31. However, Adams never had any intent of ever hiring an older gay male. <br />32. Upon information and belief, Adams, succumbing to his sexual attraction to young <br />females he supervises, decided to use the position of a Big Island Film Commissioner, over which <br />he essentially had a complete control over hiring, as a recruitment tool to satisfy his sexual <br />attraction and decided to only hire young attractive unqualified women of color so he can <br />"supervise' them and look at them daily. <br />33. Adams, upon learning about Plaintiff and his interest in the Film Commissioner, <br />even though Adams himself admitted that Plaintiff's experience and qualifications were <br />impressive, decided to pathologically lie to everyone around him and make every effort to stop <br />Plaintiff from NOT only being hired, but from even being interviewed for the position. <br />34. Since he could not admit to his desire to ONLY hire young unqualified women of <br />color to ogle them under his supervision publicly for the film commissioner position, and since he <br />could not be honest about the true nature of his planned recruiting strategy, Adams decided to <br />pathologically lie to everyone around him including Hawaii County Council members. <br />35. On October 19, 2021, already knowing of Plaintiff's interest and his impressive <br />qualifications, Adams went to the Hawaii Council and provided pathologically false testimony <br />designed to hide his sexual motivations relating to the Film Commissioner Position. <br />36. During the October 19, 2021 testimony to Hawaii County Council, Adams <br />pathologically lied to Council claiming they were actively recruiting for the Film Commissioner <br />position. <br />-7- <br />EXHIBIT "A" Pg7 <br />Page 7 of 25 <br />