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Under Article I, Section 1 of the Hawaii State Constitution, "all political power of this <br /> State is inherent in the people." The Public Trust Doctrine further mandates that gov- <br /> ernment decisions must be made transparently and in alignment with the public's inter- <br /> ests. Every public official has an obligation to uphold these principles. <br /> Mayor Mitch Roth, in assuming office, took an oath to "support and defend the Con- <br /> stitution of the United States and the Constitution of the State of Hawaii." This oath <br /> binds him to exercise his authority with transparency, accountability, and fidelity to pub- <br /> lic interest. The evidence presented herein raises significant questions about whether <br /> Roth upheld these duties. Specifically, public statements made on August 24, 2023, <br /> about the importance of community involvement in the General Plan may have misrep- <br /> resented the true extent of external influence already shaping the plan (See Section D). <br /> While Frecia Cevallos, as Deputy Director of the Department of Research and Devel- <br /> opment, may not have taken a formal oath of office, this does not exempt her from ac- <br /> countability under the law. If she knowingly concealed material facts—such as agree- <br /> ments or commitments related to ICLEI's SMART Cities initiative—this constitutes a se- <br /> rious violation of public trust. Public officials are bound by their duty to act lawfully, <br /> transparently, and in good faith. The potential concealment of such agreements prior <br /> to or during the August 24 meeting demands scrutiny, as any deliberate deception un- <br /> dermines the integrity of government operations. <br /> This affidavit will demonstrate that: <br /> • Official denials regarding SMART Cities during the August 24 meeting were in- <br /> consistent with subsequent revelations (See Section B). <br /> • Public consultation on the General Plan was portrayed as open and community- <br /> driven, while external agreements influencing the plan remained undisclosed <br /> (See Section D). <br /> • The County's participation in ICLEI's programs aligns with SMART City objec- <br /> tives, raising questions about undisclosed commitments (See Section F). <br /> These actions suggest a pattern of intentional obfuscation that compromised the <br /> transparency of the General Plan 2045 process and eroded public trust. The cumulative <br /> impact of these breaches calls into question the legitimacy of the plan itself. Both May- <br /> or Roth and Frecia Cevallos must be held to account—Roth for his constitutional oath <br /> and Cevallos for her duty to uphold the law and act in the public's best interest. <br /> Given the gravity of these concerns, this affidavit seeks the release of all records related <br /> to the County's partnerships and agreements and calls for an independent investiga- <br /> tion into the decision-making processes behind the General Plan 2045. These actions <br /> are essential to restore public trust and ensure accountability. <br />