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2009-02-02_County_of_Hawaii_v_Coupe_Family_and_Robert_Nigel_Richards_-_Memorandum_in_Opposition_to_Defendant-Appellant's_Request_for_Statutory_Damages
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2009-02-02_County_of_Hawaii_v_Coupe_Family_and_Robert_Nigel_Richards_-_Memorandum_in_Opposition_to_Defendant-Appellant's_Request_for_Statutory_Damages
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prejudgment interest is warranted; however, HRS § 101-27 does not specifically allow <br /> prejudgment interest. Hence,the award of interest of$1,900.35 should also be denied. <br /> E. Photocopying Costs Are Excessive. <br /> Coupe seeks photocopying costs in the total amount of$2,369.00. See Exhibit "B.1"of <br /> Coupe's Request for Statutory Damages, pages 1 and 2. At 20 cents per page,Coupe had copied <br /> 11,845 pages, with 6,802 pages at a total cost of$1,160.40 being an itemized charge on page 2 of <br /> the March 24, 2008, bill, see Exhibit "A"of Coupe's Request for Statutory Damages. In any <br /> event,this is a lot of sheets of paper, seemingly out of line for this appeal. <br /> As indicated earlier, Rule 39(c)(4), HRAP, allows recovery for "the cost of printing or <br /> otherwise producing necessary copies of briefs and appendices,provided that copying costs shall <br /> not exceed 20¢ per page." It is doubtful that the 11,845 pages or 6,802 pages would be the cost <br /> of printing the necessary copies of briefs and appendices. Because Coupe has failed to establish <br /> the reasonableness of the appropriate taxable costs for photocopying costs, Coupe's request for <br /> such costs should be denied. <br /> IIi. CONCLUSION <br /> For the reasons stated above, we respectfully request this Court to deny Coupe's Request <br /> for Statutory Damages for the following: <br /> 1. No Attorneys' fees for unsuccessful claims; <br /> 2. Attorneys' fees of$11,999.00 and costs of$910.87 that are itemized in the <br /> January 24, 2008, bill; <br /> 3. Costs for legal research totaling $2,115.61; <br /> 8 <br />
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