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120 P.3d 217 Page 15 <br />108 Hawai'i 318, 120 P.3d 217 <br />(Cite as: 108 Hawai'i 318, 120 P.3d 217) <br />II.motion that Jacobson later retracted the statement <br />[1] Addressing first Appellants' second point, the quoted in the opinion by rejecting the Commission's <br />challenge to Jacobson's testimony, Appellants main-plan. It should be noted that Appellants did not chal- <br />tain that this court “relie[d] upon the testimony of a lenge Jacobson's testimony in their reply brief, even <br />person who is NOT a member of the Commission[, though Defendants-Appellees, County of Hawai‘i, <br />Jacobson,] to justify the ... Commission's action be-County Clerk, County of Hawai‘i, and Lloyd Van De <br />low” and that “[s]uch reliance is inconsistent with” Car, Chairman of the Commission (collectively, <br />Dines v. Pacific Insurance Co., 78 Hawai‘i 325, 893 County Appellees), cited to Jacobson's testimony in <br />P.2d 176 (1995). (Capitalization and emphasis in their answering brief. Appellants, therefore, failed to <br />original.) However, the opinion does not state that raise Jacobson's supposed retraction of the quoted <br />Jacobson was a member of the Commission, but statement that they tardily do now. <br />identifies her as a Hawai‘i County Councilmember. It <br />may be assumed that Jacobson's testimony apprised <br />However, it appears that Jacobson had recanted <br />the Commission of how using a total population base <br />the quoted statement. Appellants state that at the <br />can achieve inclusiveness and equal representation. <br />Commission's final meeting on December 18, 2001, <br />The opinion refers to Jacobson's testimony as fol- <br />Jacobson “rejected her own statement.” (Emphasis in <br />lows: <br />original.) Upon review of the record on appeal, it <br />appears that Jacobson's December 18, 2001 testimony <br />FN3 <br />[W]e cannot say that no rational basis underlay the was never made part of the record. Appellants <br />10.89% deviation because, akin to the approach have since attached the subsequent Jacobson testi- <br />exemplified by the commission member's testi-mony to their motion as Appendix 32, as well as a <br />mony in Riley, the Commission in the instant case, declaration by their attorney, which certifies that the <br />by using “total” population, evidenced an intent to attached minutes “are public documents ... that are <br />achieve inclusiveness and equal representation. found on the County of Hawaii website at Hawaii- <br />county.com.” Although the subsequent Jacobson tes- <br />timony need not be considered by this court, seeOrso <br />... <br />v. City & County of Honolulu, 55 Haw. 37, 38, 514 <br />P.2d 859, 860 (1973) (“[A] question involving evi- <br />For at the second meeting of the Commission, <br />dence not in the record cannot be reviewed on ap- <br />**230 *331 <br />Hawai‘i County Councilmember Julie <br />peal.”) (citation omitted), in light of the fact that Ja- <br />Jacobson testified in favor of “using the population <br />cobson retracted her statement, a fact only now raised <br />as the basis for the districting,” stating that, <br />by Appellants, this court grants Appellants' request to <br />FN4 <br />strike any reference to the Jacobson testimony. In <br />each human being has needs for the government <br />doing so we observe that it is a fundamental and ele- <br />serves [sic] and it doesn't matter if you're one <br />mentary proposition that counsel is obligated to pre- <br />day old, if you're 99 years old, if you vote or <br />sent an accurate record on appeal. <br />don't vote, or any other of those variables ... each <br />person needs to be considered and I think espe- <br />FN3. County Appellees attached excerpts <br />cially with the complexity <br />from the December 18, 2001 transcripts to <br />their memorandum in opposition to Appel- <br />of infrastructure issues, that we deal with, that's <br />lants' motion for change of venue, but Ja- <br />why it's important. <br />cobson's testimony on pages 9-13 was not <br />included. <br />FN2 <br />Opinion at 328, 120 P.3d at 227. <br />FN4. In their response to the motion, County <br />FN2. Appellants attach Jacobson's June 22, <br />Appellees maintain that Jacobson's testi- <br />2001 testimony to their motion as Appendix <br />mony “was given at an earlier meeting of the <br />31, but the testimony is already part of the <br />Commission before any particular plan was <br />record. <br />before it. She later spoke in support of a par- <br />ticular plan but did not specifically address <br />Also, Appellants state for the first time in the the population issue. What she was clearly <br />© 2011 Thomson Reuters. No Claim to Orig. US Gov. Works. <br /> <br />