COM 0092.028 2004-2006 - Laserfiche WebLink

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HIATT: Okay. Did you research Corporation Counsel's opinions and find three opinions which reiterated that point? KUBOTA: Yes, I did. We got three opinions. And I believe they might have been from three different administrations, three different Corporation Counsels. But that just basically reiterated what the County's policy had been on recognition of pre-existing lots. Basically, again, if the lots existed prior to 1944, then the County would recognize it as, as legally separate lots of record. HIATT: And are those three opinions attached as Exhibits A, B, and C, to the pre-hearing brief that was filed? KUBOTA: Yes, there are. HIATT: And one was dated October 5°i, 1988, Exhibit A, correct? KUBOTA: Correct. HIATT: One was dated October 19a', 1988, Exhibit B? KUBOTA: That is correct. HIATT: And one was dated March 21 s', 1990, Exhibit C? KUBOTA: Yes. And I believe they were all signed by three different Corporation Counsel attorneys, meaning that they came from three different administrations. WATT: Okay. Okay. Now we're going to turn now to these, this application. Can you summarize for the Board what you did for your client, Continental, in representing them on these applications? KUBOTA: Yes. What we did is we obtained the area photos of plantation camps that were recognized by the Planning Director in 1995. These were ten plantation camps on the Hamakua Coast. The applicant was Hamakua Housing Corporation. And we obtained aerial photos all dated in 1990, so this is before the application was filed. The photo up here is, you know, one of the representative photos. We'll go through each of them. But what we did is we had someone overlay the tax map lots that were resulted from the application that was granted to Hamakua Housing so we could show how the lots were subdivided in that application. HIATT: David, in that little tackle box over there, there's a pointer, laser pointer. If you can find it for me, that would be great. Not that one. Excuse me. 10