2006-01-25_Dan_Cole_v._County_of_Hawaii_-_Order_Granting_Defendants_Motions_to_Dismiss

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Case 1:05-cv-00325-JMS-BMK Document 35 Filed 01/25/2006 Page 13 of 24 2. Cole met with several County officials on May 28, 2004, at which time Cole presented evidence of fraud against the United States and evidence of illegal acts of dumping; 3. On June 4, 2004, Lincoln S.T. Ashida, Corporation Counsel for the County, wrote a letter to the Attorney General of Hawaii in which Ashida asked the Attorney General to initiate an investigation into Cole's allegations; 4. On March 15, 2005, Cole met with Hawaii County Police Department Officer Jason Grouns. Cole wished to file a complaint against State officials for having threatened and/or harassed him, but Officer Grouns and other County officials refused to initiate a complaint; 5. In March and April of 2005, Cole contacted the County Prosecutor's office to discuss this matter. Cole alleges that the Deputy Prosecuting Attorney with whom he spoke violated his constitutional rights, although Cole does not explain how his rights were violated; and 6. The Defendants have been and continue to be involved in a conspiracy to deprive Cole of his constitutional rights.2 2 Cole also alleges that Steven Y.K. Chang, Chief of the Solid and Hazardous Waste Branch of the State of Hawaii's Department of Health, sent him a threatening and intimidating letter dated August 19, 2004. As the court stated, Cole's claims against the State are barred by 13