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Molly A. Stebbins, Esq. Corporation Counsel Brenda J.Ford v. Bobby Jean Leithead-Todd S.P.No. 13-1-52K FORMAL REQUEST FOR REIMBURSEMENT OF ATTORNEY'S FEES AND COSTS July 8,2015 Page 2 Ford v. Leithead-Todd, S.P. 13-1-34K I had previously represented Bobby Jean Leithead-Todd in Ford v. Leithead- Todd, deemed S.P. 13-1-34K. In that action on September 6, 2013, the County of Hawaii filed a Motion To Intervene. In its Motion to Intervene, the County argued that it had a significant interest in assuring that the actions of the executive and legislative branches were not undermined or invalidated. The County argued further that it had a significant interest in having its Directors remain in their positions without interference or interruption. The County argued that the interests of Ms. Leithead-Todd and the County were likely aligned. On September 27, 2013, the circuit court issued an Order Denying County of Hawaii's Motion to Intervene. On September 9, 2013, I filed on Ms. Leithead-Todd's behalf, a Motion to Dismiss Petition. On October 23, 2013, a hearing was held on Ms. Leithead-Todd's Motion to Dismiss. The circuit court dismissed the Petition in S. P. No. 13-1-34K. The dismissal was without prejudice. I had submitted a letter seeking reimbursement of fees and costs my legal work provided in S.P. 13-1-34K, in a letter dated February 6, 2014, to then Corporation Counsel Lincoln Ashida. Mr. Ashida presented the reimbursement request to the Hawaii County Council, and said body graciously approved the application for reimbursement, and my firm was paid for the work undertaken in S.P. 13-1-34K. Ford v. Leithead-Todd, S.P. 13-1-52K On December 9, 2013, Petitioner Brenda J. Ford filed a second Petition for Quo Warranto in S.P. No. 13-1-052K. I continued to represent and defend Bobby Jean Leithead- Todd, Director of the Department of Environmental Management for the County of Hawaii. The County had not sought to intervene in this case. This second case involved a decision on the merits, and required significant work to obtain a judgment in favor of Bobby Jean Leithead-Todd. On May 26, 2015, the circuit court issued Findings of Fact, Conclusions of Law, and Order Granting Respondent Bobby Jean Leithead-Todd's Motion for Summary Judgment In Favor of Respondent On The Verified Petition Of Brenda J. Ford ("Petitioner") For An Order In The Nature Of Quo Warranto Directing The Respondent Bobby Jean Leithead-Todd To Show The Authority Under Which She Purports To Hold The Office Of Director Of The Department Of Environmental Management