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Limited Partnership("Coupe Family"),by and through its attorneys,Damon Key Leong Kupchak <br /> Hastert,respectfully submits its Response to 1250 Oceanside,LLC's ("Oceanside")Objections to <br /> the BOA'S Proposed Amended Findings of Fact, Conclusions of Law,Decision and Order, served <br /> January 23, 2026 ("Proposed Decision and Order"), and its Proposed Supplemental Edits to the <br /> Board for consideration to incorporate into the Board's Proposed Decision and Order. A copy of <br /> the Board's Proposed Decision and Order with Coupe Family's suggested edits is attached as <br /> Exhibit"A". <br /> I. RESPONSE TO OCEANSIDE <br /> A. Proposed Findings of Fact <br /> Proposed Finding of Fact Objections <br /> 3. On May 28, 2024, 1250 Oceanside, LLC Oceanside objects to Proposed FOF 3 on <br /> ("Appellant") filed its General Petition the grounds that it mischaracterizes and <br /> for Appeal of Decisions by Planning misstates the grounds for Oceanside's <br /> Director or Public Works Director appeal of the Declaratory Order. <br /> ("Appeal")with the Board of Appeals, As reflected in its General Petition for <br /> County of Hawaii ("Board") appealing Appeal of Decisions by Planning Director <br /> the Planning Director's issuance of the or Public Works Director filed on May <br /> Order. Appellant argued the following 28, 2024 ("Petition for Appeal"), <br /> points of error: Oceanside appealed the Declaratory <br /> a. Planning Director erred by not Order on the grounds that: <br /> interpreting Ord. 96-7, standing a. The Director erred by ruling that <br /> alone, because no dedication Ordinance No. 96-7 requires the <br /> requirement is contained within dedication of three roadways <br /> Ord. 96-7; because no such requirement is <br /> b. Planning Director erred by contained within Ordinance No. 96- <br /> seemingly qualifying the 2010 7' <br /> dedication of the Mauka Haleki`i b. The Director erred by seemingly <br /> Extension and corresponding qualifying the 2010 dedication of the <br /> satisfaction of the Ordinances' Mauka Haleki`i Extension and <br /> conditions related to the roadway; corresponding satisfaction of the <br /> and Ordinances' conditions related to the <br /> c. Planning Director erred by ruling roadway; and <br /> that the Makki Haleki`i Extension <br /> and Connector Road have not been <br /> 2 <br />