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5. There is an actual controversy between the parties <br /> on this matter which justifies the granting of declaratory <br /> relief pursuant to HRS Chapter 632. <br /> 6. Plaintiff Claudia ROHR is a resident of South <br /> Hilo, County and State of Hawaii whose interests will be <br /> harmfully affected by the passage of Bill 356. <br /> 7. Defendant COUNTY COONCIL is the legislative body <br /> of the County of Hawaii, whose purviews are set forth in <br /> the Hawaii County Charter, Article III. <br /> 8. Defendants JOHN DOES 1-10, JANE DOES 1-10, DOE <br /> GOVERNMENT AGENCIES 1-10 are unknown to Plaintiff, who <br /> therefore sues said Defendants by such fictitious names and <br /> ask leave of the Court to amend this complaint to <br /> substitute the true names and capacities when same become <br /> known. <br /> IV FACTUAT ALLEGATIONS <br /> <br /> ACS? <br /> 9. Claim I concerns the Hawaii County Council's <br /> <br /> procedural irregularities in the review and approval of use <br /> of the April 12 Settlement Agreement for Board of Appeals <br /> and Subdivision of Continental Pacific LLC's land and <br /> <br /> public access spacing to the shoreline in Continental <br /> Pacific, LLC's Pepe'ekeo Makai subdivision in Pepe'ekeo, <br /> <br /> Hawaii. <br /> 3 <br /> <br />