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300-iV, V. VI, and VII; GO 300A-IV: GO 605-III. IV. V, V1. VII and VIII. and HRS 707-710 <br /> and/or 707-711and/or 707-712, 707-713 and/or 707-714: 707-721and/or 722. Clark <br /> further violated env statute or rules that prohibit obtaining signatures from priso- <br /> ners under duress. as he did twice. Plaintiff presently cannot name specifics but <br /> will do so later. except that his intimidation and threats violated Plaintiff s civil <br /> rights and due process rights as laid down in the Constitutions of Hawaii and the <br /> United States. it was a criminal act. Hickman is responsible for his own participa- <br /> tion in the above violations as well as for those of the policemen in his command. <br /> Cleric and Kealoha. under the doctrine of respondeat superior and GO 302x1. <br /> Hickman is also solely responsible for the filthy detention cell in his police station <br /> and thus violated GO 301-11.-C.~. and 301-1. <br /> COUNT 5. - RESPONDEAT SUPERIOR OF CHIEF OF POLICE AND MAYOR <br /> 33. UNDER THE DOCTRINE OF RESPONDEAT SUPERIOR DEFENDANT <br /> CHIEF OF POLICE CARVALHO IS CO-RESPONSIBLE FOR ALL THE ABOVE, EVEN <br /> IF HE WAS NOT PERSONALLY INVOLVED. He writes and/or maintains the "General <br /> Orders", which are mainly about proper procedures and discipline of his troops. In many <br /> cases their education and training was and still is insufficient, discipline and supervision <br /> are lacking or insufficient, many policemen like Lally, Kimura, Kealoha, Clark and Hick- <br /> man have scant or no knowledge of state laws, let alone current Hawaii Supreme Court <br /> decisions (case law), or if they do know, violate them, not by accident but because there <br /> exists a kind of cowboy mentality among many who feel that they have to rule the public <br /> instead of to protect it, they feel powerful because of their guns; and there is insufficient <br /> enforcement of the General Orders. <br /> 34. An unofficial and misdirected "buddy" system, where police cover up each <br /> other's mistakes and bend laws and rules, combined with the "kill haole" mentality that is <br /> manifest on the BIG ISLAND detracts many policemen from their real duties -misplaced <br /> hostility is rife. Haole policemen like Lally and Clark want to be accepted by the "local" <br /> police as "buddies" and obviously try to do this by being more vigorous and hostile with <br /> <br /> the haole public than others. Lally who knew that Kimura would be transporting Ross to <br /> f~ <br /> <br />