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POTENTIAL LAWSUITS <br /> We believe that IFthe Windward Planning Commission adopts the proposal submitted by Manono <br /> Corner,LLC, WITHOUT Conditions of Approval attached to the zoning request,we can file two(2) <br /> lawsuits: <br /> (1) A lawsuit against the County of Hawaii for an unconstitutional taking reducing the value of our <br /> property <br /> AND <br /> (2) A lawsuit against the landowner for creating an attractive nuisance. <br /> We believe the Planning Department has and continues to engage in "spot zoning" If the Waiakea <br /> House lots area is envisioned to transition into MCX zoning as described in the General Plan,then the <br /> Planning Department should begin the process of rezoning the entire area,instead of individual lots on <br /> an ad hoc basis. Spot zoning in the last twenty years in the Waiakea House Lots subdivision has <br /> produced a variety of zoning designations inconsistent with the General Plan for MCX industrial/ <br /> commercial zoning of the entire area. <br />