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Kamuela need not have done apat-down or body search as it turned out, but apart from <br /> other motives, he obviously was showing off how brutal he could be with another haole. <br /> 35. Although the last two recruit classes have been psychologically profiled, all <br /> policemen in this case were never examined for suitability to their jobs or hidden perso- <br /> nality problems, as is done on Oahu and Maui. And there is definitely something wrong <br /> with the police force as long as people like Plaintiff without a criminal record (and too old <br /> even to have committed the indicated crime) can be and are brutalized without probable <br /> cause and picked up from the street without due process of law and in violation of the <br /> GO, the laws and Constitution, on the whim and false accusations (without witnesses or <br /> any visible signs of violence) of immature grocery store clerks, whose personnel records <br /> show severe shortcomings in dealing with customers and who lack store dicipline to an <br /> extent that their defiance of management's admonitions then subsequently leads to their <br /> firing, as happened in Schutte's case: fired later for ongoing insubordination by KTA. <br /> 36. Chief Carvalho and the County of Hawaii are responsible for all violations of <br /> law by their employees as shown supra, under the doctrine of Respondeat Superior. And <br /> the Mayor of the Country is equally responsable in a respondeat superior capacity, as he <br /> is, pursuant to the Hawaii County Charter, the administrative head of the police and has <br /> manipulated the police budget in a way that insufficient money is available for adequate <br /> supervision, training, psychological profiling and testing for suitability of all individuals. <br /> 37. DEFENDANTS STEPHEN K. YAMASHIRO AND WAYNE G. CARVALHO. <br /> RESPECTIVELY AS MAYOR AND CHIEF OF POLICE OF THE COUNTY OF HAWAII. <br /> AND THE COUNTY OF HAWAII ITSELF are therefore liable for all violations. that <br /> are cited above in items 18.23.26 and 32, as oer~etrated by their em~lovees. <br /> COUNT 6 -CONTINUED MANIPULATION OF FACTS AND TESTIMONIES <br /> 38. After Ross had been taken back to his car at about noon, Clark went back <br /> to KTA, where the store manager who had been absent when Schulte attacked Ross that <br /> morning had already had meetings with KTA personnel to all speak the same language <br /> <br /> to the police when investigated, a kind of indoctrination that is usually done under such <br /> <br /> circumstances and amounts to conspiracy. And Clark obviously felt that he must make <br /> f2 <br /> <br />