2026 06 10_Appellant Ohana's Objections to Record, Rosehill Dec, and COS_v1.pdf

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materially incomplete. The `Ghana requests that the Board of Appeals (the "Board") order the Director to supplement the Record with all records in the Director's file directly related to the decision to approve the Applicant's SMA Minor Permit, including but not limited to the documents identified below. The Record on Appeal is "a compilation of public records from the department that are directly related to the Director's decision for the appeal in question." County of Hawaii Board of Appeals Rules of Practice and Procedures ("BOA Rules") § 1-3(21). "[T]he entire record or file from the Director shall be submitted to the Board and other parties ..." BOA Rules § 3-13(h) (emphasis added). Documents that were in the Planning Department's file and are directly related to the Director's decision issued December 4, 2025 approving SMA Minor Permit PL-SMM-2025- 000079 (the "Decision") must be included. II. MISSING OR INCOMPLETE DOCUMENTS The `Ghana objects that the Record on Appeal is incomplete as to the full scope of the Planning Department's files related to the subject property, TMK No. (3) 1-2-018:001, and to the activities of Kaimu Cove, LLC (the "Applicant") thereon. As set forth above, BOA Rules §§ 1- 3(21) and 3-13(h) require the Director to submit the entire file directly related to the Decision. The `Ghana has good reason to believe the Record as filed is incomplete. Following the October 3, 2024 Windward Planning Commission (the "Commission") hearing, `Ghana member Leslie Enriquez Rosehill requested from the Planning Department all plans, permits, and history associated with the subject property. In response to that request, Ms. Rosehill was provided access to the Planning Department's file and was able to review documents in it relating to the property and the pending application(s). Her access was withdrawn on or around December 2025. 2