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2006-12-18_Planning_Department_Reply_Brief_re_Calvert
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2006-12-18_Planning_Department_Reply_Brief_re_Calvert
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0 a <br /> undersigned counsel, AMY G. SELF, Deputy Corporation Counsel,pursuant to Hawaii <br /> Revised Statutes ("HRS") § 91-14 and Rule 72 of the Hawaii Rules of Civil Procedure,. <br /> respectfully submits his Reply Brief in accordance with the Briefing Schedule established <br /> by the Court and filed on August 17, 2006, as amended by the Stipulation and Order <br /> extending the time for the Director to file his reply brief filed December 14, 2006. <br /> I. ARGUMENT <br /> A. The Director is not Precluded from Judicial Review for Failure to <br /> Obiect to the Proposed Finding of Fact and Conclusions of Law. <br /> HRS § 91-14(a) sets forth the following jurisdictional requirements for an agency ' <br /> appeal: <br /> (1) The proceeding that resulted in the unfavorable agency action must have <br /> been a contested case hearing that was required by law and determined the <br /> rights, duties, and privileges of specific parties; <br /> (2) The agency action must represent a final decision and order or a <br /> preliminary ruling that such deferral of review would deprive the claimant <br /> of adequate relief; <br /> (3) The claimant must have followed the applicable agency rules and have <br /> been involved in a contested case hearing; and <br /> (4) The claimant's legal interest must have been injured--i.e.,the claimant <br /> must have standing to appeal. <br /> Hui Kako`o Aina Ho`opulapula, et al. v. Board of Land and Natural Resources, et al., <br /> 112 Haw. 28, 35, 143 P.3d 1230, 1237 (2006). <br /> Appellees' reliance on the court's decision in Hui Kako`o Aina Ho`opulapula for <br /> the supposition that this Court may lack jurisdiction to conduct judicial review of the <br /> appeal filed by the Director because the Director failed to raise timely objections to the <br /> Findings of Fact and Conclusions of Law ("FOFCOL")proposed by Appellee/Appellant <br /> 2 <br />
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