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I. INTRODUCTION <br /> Pursuant to Rules 3-20 and 8-14 of the County of Hawaii Board of Appeals ("BOA") <br /> Rules of Practice and Procedures ("BOA Rules"), Appellant 1250 Oceanside, LLC <br /> ("Oceanside"), by and through its attorneys, Carlsmith Ball LLP, hereby submits its Objections <br /> to the County of Hawaii Board of Appeals' Proposed Amended Findings of Fact, Conclusions <br /> of Law, Decision and Order, served January 23, 2026 ("Proposed Decision and Order"). <br /> By submitting these Objections, Oceanside does not waive any arguments that the <br /> Findings of Fact, Conclusions of Law, Decision and Order ultimately adopted by the BOA fails <br /> to satisfy any and all applicable legal requirements, including those under Haw. Rev. Stat. <br /> ("HRS") § 91-12, or that the County ofHawai`i Planning Director ("Planning Director") and/or <br /> BOA otherwise erred in rendering their respective decisions. <br /> iI. GENERAL OBJECTIONS <br /> A. THE PROPOSED DECISION AND ORDER CONTAINS NUMEROUS <br /> FINDINGS AND CONCLUSIONS THAT ARE COMPLETELY UNRELATED <br /> TO THIS APPEAL. <br /> The Proposed Decision and Order contains numerous proposed FOFs and COLS that are <br /> completely unrelated to this appeal, which concerns Oceanside's appeal of the Declaratory Order <br /> issued in response to Tntervenor- C& J Coupe Family Limited Partnership's ("Coupe") Petition <br /> for Declaratory Ruling filed on February 7, 2024, and its Supplement to Petition for Declaratory <br /> Ruling filed on March 27, 2024 (together, "Coupe's Petitions for Declaratory Ruling"). See, <br /> e.g., Proposed FOFs 11, 12, 14 & 15; Proposed COLS 5, 6, 9 & 11. As explained further below, <br /> these proposed FOFs and COLS appear to relate to the issues raised in Oceanside's separate <br /> appeal in Case No. PL-BOA-2024-000105, which concerns the Declaratory Order issued in <br /> response to Oceanside's Petition for Declaratory Ruling. These proposed FOFs and COLS are <br /> irrelevant to the BOA's decision to affirm the Declaratory Order at issue in this appeal, and <br /> 2 <br /> 4906-3356-8652.1.051730-00058 <br />