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ROBERT D . S . KIM , INC . <br /> A Hawaii Law Corporation <br /> 81 -6627 Maiimalahoa Hiy,hway, Ste. 1 (191P.O. Box 188 Kealakekua, HE 96750 <br /> Phonic: 808.329.ti61"l Fax: 808.32_9.6676 <br /> Erna ii: konalawl@hawaii.rr.com <br /> July 8, 2015 <br /> Molly A. Stebbins, Esq. <br /> Corporation Counsel <br /> County of Hawaii <br /> Hilo Lagoon Centre <br /> 101 Aupuni Street, Unit 325 <br /> Hilo, Hawaii 96720 <br /> RE: Brenda J. Ford v. Bobby Jean Leithead-Todd; S. P. No. 13-1-52K <br /> FORMAL REQUEST FOR REIMBURSEMENT <br /> OF ATTORNEY'S FEES AND COSTS <br /> Dear Ms. Stebbins: <br /> I am the retained counsel for Bobby Jean Leithead-Todd, Director of the <br /> Department of Environmental Management for the County of Hawaii. My law firm was <br /> privately retained by Bobby Jean Leithead-Todd to defend her in the above referenced civil <br /> action. <br /> Our law firm defended Ms. Leithead-Todd against the Petition Of Brenda J. Ford <br /> For An Order In The Nature Of Quo Warranto Directing The Respondent BOBBY JEAN <br /> LEITHEAD-TODD To Show The Authority Under Which She Purports To Hold The Office Of <br /> Director Of The Department Of Environmental Management For The County Of Hawaii Filed <br /> December 9, 2013 ("Petition"). <br /> The history in this matter reveals that, on or about June 3, 2013, the Mayor of the <br /> County of Hawaii, by Communication 326 and Communication 326.1, nominated Respondent <br /> Bobby Jean Leithead-Todd to serve as the Director of Environmental Management for the <br /> County of Hawaii. <br /> On July 10, 2013, at a duly noticed meeting of the County Council, six of the <br /> County Council's nine members voted to confirm the Respondent's nomination to serve as the <br /> Director of Environmental Management for the County of Hawaii, while three of the County <br /> Council's nine members, including Petitioner, voted against the nomination. <br /> At all times, Bobby Jean Leithead-Todd was acting in her official capacity, being <br /> duly qualified and confirmed by the Hawaii County Council. She had been sued to remove her <br /> from office, despite the foregoing procedural history. <br />