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

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As was discussed at the pre-hearing conference, DPW did not provide the Record on Appeal until September 13. Although DPW has now provided the Record, we believe that it is unfortunately incomplete. We will be filing objections on the deadline this Friday. In the meantime, we served a public record request(UIPA) on August 30, but DPW has not responded with a production of records within 10 business days, as required under HRS Chapter 91 and the Office of Information Practice's administrative rules. See https://oip.hawaii.gov/laws-rules-opinions/rules/quick-guide-to-oips-administrative-rules/. In short: (1)the Record on Appeal does not contain all records lo Processing needs; and (2) the UIPA request seeking additional records is pending/overdue and we have no idea if or when DPW may comply. Given the upcoming exhibit and witness list deadlines (on 9/27), we would like to discuss these matters with the Chair, including whether she or the Board would be amenable to issuing a document subpoena for evidence that to Processing needs for the hearing. Our hope is that we can work with the BOA and DPW to get all relevant evidence and then proceed with the October 11 hearing. Thank you, Ian From: Agustin, Noah [mailto:Noah.Agustin@hawaiicounty.gov] Sent: Monday, September 9, 2024 3:55 PM To: Ian R. Wesley-Smith Cc: Patrick K. Wong; Tavares, Sherilyn K.; Lactaoen, Kawehilani S; Wan, Sylvia A; SalasFerguson, Sinclair Subject: RE: Io Processing BOA Prehearing Conference CAUTION:This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Good Afternoon, Ian, Please find attached the Zoom link for tomorrow's pre-hearing conference. Let me know if you have any questions. The Office of the Corporation Counsel is inviting you to a scheduled ZoomGov meeting. Topic: SAW: Pre-Hearing Conference re: l'o Processing Company, BOA 23-065 Time: Sep 10, 2024 09:00 AM Hawaii Join ZoomGov Meeting https://www.zoomgov.com/j/1613581365?pwd=M nFnN FRpN U1 oZS9mM29veXhKTFJsUTO9 Meeting ID: 161 358 1365 Passcode: 691970 One tap mobile +16692545252„1613581365# US(San Jose) +16692161590„1613581365# US(San Jose) 4