2024-09-25 Appellant's Request for Subpoena Duces Tecum, Exhibit 1-2

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In February 2022, before I`o Processing purchased the Facility, Ms. Nichole Kanda2 met with staff of DPW, Building and Engineering Divisions. At that time, Ms. Kanda provided DPW with the Processing Facility's construction plans. DPW Building Division verbally confirmed that the Processing Facility did not require building permits and would be entitled to an agricultural exemption under HRS § 46-88, but would need an electrical permit to connect to County power lines. Based on DPW's pre-approval, I`o Processing proceeded with getting final approvals for various aspects of the project over the next ten months without issue: • On March 17, 2022, I`o Processing applied for an electrical permit for the Facility, per DPW's recommendation. In connection with the electrical permit, I`o Processing submitted design plans that clearly identified the Facility. • On July 27, 2022, the electrical rough-in work passed inspection, including a site visit to the Facility. • On August 8, 2022, the electrical underground work passed another inspection, with another site visit, and was installed. • On August 24, 2022, DPW accepted declarations of compliance for related compost structures. • On October 28, 2022, I`o Processing was issued Building Permit No. PW-B2022- 003346 for a related Agricultural Office Building. • On September 21, 2022, I`o Processing filed, and DPW accepted, a declaration of compliance for a related Agricultural Shed. Through all these repeat interactions, involving review of plans, site visits, and multiple conversations, DPW never raised any issue with the Facility. Accordingly, at every step I`o Processing continued to proceed based on the assurances previously provided by DPW in February 2022. I`o Processing's problems with DPW began abruptly on December 29, 2022, when Mr. 2 Ms. Kanda is I`o Processing's principal. 5 4871-5206-8494.1.071717-00001