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2026-05-12 Appellant's Memorandum in Opposition to Motions to Dismiss (PL-BOA-2025-000119 & 121)
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2026-05-12 Appellant's Memorandum in Opposition to Motions to Dismiss (PL-BOA-2025-000119 & 121)
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JEFS page 16, ROA 391-393), the Appellee Board of Appeals' Order in the Ford <br /> Appeal does not contain a ruling on the Appellants' proposed findings and <br /> conclusions of law described in Section 91-12, Hawaii Revised Statutes. 24 <br /> B. <br /> AGENCY APPEAL TO THIS COURT <br /> 1. On May 23, 2023, the Appellants Ford, et al. and Gage filed <br /> a joint agency appeal from the Appellee Board of Appeals' Orders with this <br /> Court pursuant to Section 91-14(b), Hawaii Revised Statutes and Rule 72, <br /> Hawaii Rules of Civil Procedure. (Dkt. 1) <br /> 2. In their joint Statement of the Case (ROA Dkt. 3), the <br /> Appellants Ford, et al. and Gage contend that the Appellee Board of Appeals <br /> erred because the Board had acted in violation of constitutional or statutory <br /> provisions, in excess of its statutory authority or jurisdiction and upon <br /> unlawful procedure. They also contend that the Appellee Board of Appeals' <br /> Orders in question are affected by other error of law, are clearly erroneous in <br /> view of the reliable, probative, and substantial evidence on the whole record <br /> and are arbitrary, or capricious, or characterized by abuse of discretion or <br /> clearly unwarranted exercise of discretion. <br /> 3. In their Opening Brief (Dkt. 58) the Appellants Ford, et al. <br /> and Gage contend that the Appellee Board of Appeals erred when it: <br /> a. considered the Appellees Neal and Zanone's motion for <br /> summary judgment because such a motion is not an authorized pleading <br /> or procedure and because the Appellees Neal and Zanone are not entitled <br /> to summary judgement even if their motion is an authorized pleading or <br /> procedure; <br /> 24 ... If any party to the proceeding has filed proposed findings of <br /> fact, the agency shall incorporate in its decision a ruling on each <br /> proposed finding so presented. ..." <br /> 21 <br />
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