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DeVera, Ashley <br /> From: SalasFerguson, Sinclair <br /> Sent: Monday, September 30, 2024 10:22 AM <br /> To: Planning Board of Appeals <br /> Cc: Ian R. Wesley-Smith; Patrick K. Wong; Lactaoen, Kawehilani 5; Pause, Stephen (Steve); <br /> Kekai, Mafia; Mendonca, Ashlee; Tavares, Sherilyn K. <br /> Subject: 1'O Processing vs. DPW, PL-BOA-2023-000065: request for continuance of hearing set <br /> for October 11, 2024 <br /> Attachments: #1 Complaint.pdf; #9 Order Putting COH's in Possession.pdf; #19 Def Kapoho's Mtn <br /> to Vacate Order Putting COH in Possession.pdf <br /> Good Morning, <br /> I am writing to request a continuance of the above referenced appeal, due to the following: <br /> • Steve in unable to attend the October 11, 2024 hearing date in the above referenced matter because he <br /> has to attend an unexpected hearing for a significant condemnation case, in Hilo Circuit Court, on October <br /> 11, 2024, at 10:00 a.m.; <br /> • Significant Condemnation Case: <br /> o In 2018, in cooperation with FEMA and other relevant agencies,the County started planning for the <br /> Pohoiki Road and Highway 137A Road Repair and Water Line Installation Project; <br /> o On July 8, 2024,the County was forced to file an eminent domain action in Circuit Court, seeking <br /> condemnation of property owned by Kapoho Land Company:the property is required by the County <br /> to reconstruct Pohoiki Road (see attached complaint); <br /> o On August 15, 2024,the Circuit Court issued an order, placing County in possession of the <br /> property, so that County could continue with the road reconstruction project(order is attached); <br /> o On August 26, 2024, Kapoho Land Company filed a motion to vacate the order that put County in <br /> possession of the land (attached); <br /> o On September 26, 2024, Steve Pause received notice that he is required to attend a hearing on <br /> Kapoho Land Company's motion on October 11, 2024, at 10:00 a.m. in Hilo Circuit Court; <br /> This Circuit Court hearing is significant to the County because if the Court denies Kapoho Land Company's <br /> motion,the County can proceed to put the Pohoiki Road Reconstruction project out to bid (solicit a contractor to <br /> reconstruct the road). <br /> Additional information and reasoning in support of DPW's request for a continuance: <br /> My understanding is that this matter was continued in the past because Steve was working directly with Nicole <br /> Kanda (I'O's principal)to resolve this matter,which led me to believe that this appeal would be settled. <br /> Settlement was not reached, and now 1'O Processing would like to proceed to a hearing. <br /> However, I think the parties need more time to resolve the following litigation issues: <br /> 1. 1'O Processing submitted a request for documents to DPW,which DPW is working towards fulfilling—I <br /> think it is prudent if all parties have sufficient time to review whatever is produced by DPW. <br /> 2. DPW and 1'O Processing are not in agreement as to which County witnesses are relevant;therefore, DPW <br /> anticipates 1'O Processing will ask the BOA for subpoenas, requiring certain County employees to attend <br /> the hearing—I think a continuance would give the parties and the BOA ample time to address these issues. <br /> 3. I think it is important that the parties have sufficient time to research and draft their respective prehearing <br /> statements because the issues involved in this appeal are complex, which makes it more challenging to <br /> simplify. <br /> Additionally, last Friday, Sept. 27, 2024, DPW contacted 1'O Processing, requesting an in-person meeting to reach <br /> a final resolution to this matter. <br /> Finally, on Sept. 27, I raised Steve's scheduling conflict with I'O's attorney, and was informed that he could not <br /> agree to a continuance. <br /> 1 <br />