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answer is no, then I think we can move on. If the answer is yes, then I think it’s going to really <br />require a really good hard look at this whole issue of how the public is going to get into this <br />subdivision; and that’s some things that we’ve been trying to talk to Chris about that we have not <br />yet been able to come to a clear agreement on. So that’s kind of where we’re at in this process <br />today. <br />WOODWARD: Any further questions for any of the testifiers? Yes, Commissioner <br />Iwashita. <br />IWASHITA: Thank you, Mr. Chair. I forgot to ask earlier about if there are any <br />CC&Rs in the subdivision that would be a further impediment for, you know, for public access. <br />YEH: You know, I haven’t looked at the CC&Rs recently. There are CC&Rs, <br />but whether they apply to this particular road issue I’m not sure. There, and John, go ahead. <br />J. BARSELL: As far as I know there are no CC&Rs. <br />IWASHITA: Well, you have an Association that maintains -. <br />J. BARSELL: We have Bylaws. We have a Declaratory Judgment from the Court which <br />lays out how our subdivision should be administered, but we have no CC&Rs. <br />IWASHITA: So in the Dec Action and the Bylaws there is no restriction as far as <br />owner’s use of the subdivision roads? The question, the issue that I’m trying to raise and trying <br />to get clarification on is I’m going to project out into the future, right, that there’s a court action <br />and the court decides that in part based upon this 1880 map that under the Act of 1892 that the <br />road designated on the map, you know, basically is a public road, and so the public has a right to <br />use that road. And I guess the way, I’m looking at how that road goes.It basically shoots down <br />pretty close to where your property is, but definitely within this subdivision. Right? Once <br />there’s a public road from Pohoiki Road down to the shoreline, which is basically what that road <br />shows, then the question becomes what rights there are beyond that actual road, that is all these <br />subdivision roads now, right? Is there anything in the Dec Action Order or, you know, <br />otherwise, the Bylaws establishing the Association that controls those road that would limit the <br />public’s right to use those roads and, you know, to get access, to any access if we decide to <br />provide access across this property? <br />YEH: Okay. I see your question. Well, first of all, those Bylaws were actually <br />recorded as covenants that applied to, and those Bylaws were recorded September of ’01. The <br />Association in the Bylaws does have the authority to control management, maintenance of those <br />roads. The problem with this access issue is that, yes, if -. And I don’t necessarily know, I don’t <br />have a crystal ball, but I have my own opinions as to whether or not a Court would adopt the <br />conclusion that there was a public road. But even assuming that it did, it would have to locate <br />where that road goes to. And beyond that work, the public from a legal standpoint would not <br />have a right to traverse any roads within that subdivision, that’s for sure. And then we’re going <br />to be in a trespass situation. <br />IWASHITA: Thank you for that clarification. That’s, you know, to use Commissioner <br />Bowman’s fence picture, analogy, I share her concern about, one, allowing for public access on <br /> EXHIBIT B <br />13 <br /> <br />