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2024-10-03 Chair Grants Time Extension to File Responsive Exhibits by October 7, 2024
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PL-BOA-2024-000105 1250 Oceanside, LLC (PD)
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2024-10-03 Chair Grants Time Extension to File Responsive Exhibits by October 7, 2024
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have had a deadline of the 28th from the offset. We raised no issue and, as mentioned above, filed our exhibits on the <br /> 25th. <br /> In any event, the Intervenor's sole interest here is a full adjudication of the issues which can only be carried out with a <br /> complete and accurate evidentiary foundation. Thus, we request that you disregard Oceanside's objection, and, for the <br /> same reason, Intervenor has no objections to either Oceanside's supplementary exhibits (untimely filed on the 25th), nor <br /> any additional documents they wish to file in response to our timely Responsive Exhibits. <br /> Sincerely, <br /> Toren <br /> Toren K. Yamamoto I Attorney <br /> Office: (808)531-8031 <br /> Fax: (808)533-2242 <br /> Mail: tky@hawaiilawyer.com <br /> Web: www.hawaiilawyer.com <br /> Addr: 1003 Bishop St,Ste 1600 <br /> 131MERITAS° <br /> Honolulu, HI 96813 <br /> LAW FIRMS WORLDWIDE <br /> D.\, i() , KED` [I..(.)NG KLIF'. HAK HASTERT hawaiilowyer.com <br /> Confidentiality Notice:This email message,including any attachments,is for the sole use of the intended recipient(s)and <br /> may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution is <br /> prohibited.If you are not the intended recipient,please contact the sender by reply e-mail and destroy all copies of the <br /> original message.Thank you. <br /> FRAUD ALERT—PLEASE CALL YOUR DAMON KEY CONTACT TO VERIFY ANY EMAIL OR FAX REQUESTS FOR WIRE <br /> TRANSFER PAYMENTS,WIRING INSTRUCTIONS,OR CHANGES TO WIRING INSTRUCTIONS THAT APPEAR TO BE FROM <br /> OUR FIRM. <br /> From: Derek B. Simon <dsimon@carlsmith.com> <br /> Sent: Wednesday, October 2, 2024 1:14 PM <br /> To: 'Planning Board of Appeals' <boardofappeals@hawaiicounty.gov> <br /> Cc: Wan, Sylvia A<SylviaA.Wan@hawaiicounty.gov>; Campbell,Jean K<JeanK.Campbell@hawaiicounty.gov>; Bailey, <br /> Elizabeth B. <ElizabethB.Bailey@hawaiicounty.gov>; Kenneth R. Kupchak<krk@hawaiilawyer.com>; Mark M. Murakami <br /> <mmm@hawaiilawyer.com>;Toren K. Yamamoto<tky@hawaiilawyer.com>; Patrick K. Wong<pwong@carlsmith.com>; <br /> Ian R. Wesley-Smith <iwesley-smith@carlsmith.com>; Cynthia Y. Arashiro<carashiro@carlsmith.com> <br /> Subject: FW: In the Matter of Appeal of 1250 Oceanside, LLC Case Nos. PL-BOA-2024-000104 & PL-BOA-2024-000105 - <br /> Intervenor's Exhibit Lists <br /> Dear Chair Lewis: <br /> On behalf of Appellant 1250 Oceanside, LLC, I am writing to object to Intervenor C &J Family Limited Partnership's late <br /> filing of its responsive exhibits and to request additional time to submit responsive exhibits. <br /> The BOA's Scheduling Order issued September 11th set clear deadlines for the filing of exhibits. Initial exhibits were to <br /> be filed and served no later than 4:30 p.m. on September 18th, and responsive exhibits were required to be filed and <br /> served no later than 4:30 p.m. on September 25th. Intervenor did not file any exhibits prior to either the September <br /> 18th initial exhibit deadline or the September 25th responsive exhibit deadline. Instead, at 9:44 p.m. on September <br /> 26th, Intervenor emailed its exhibit lists and responsive exhibits, which total 540 pages. A copy of that email is below. <br /> We object to Intervenor's exhibits because: (1)they are not responsive to Appellant's or Appellee Planning Director's <br /> exhibits, but instead are clearly initial exhibits that relate to Intervenor's case before the Board, and should have been <br /> 2 <br />
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