HomeMy WebLinkAboutAppellee01 - Director, DEM's Witness-Exhibit list + COSELIZABETH STRANCE 4715 Corporation Counsel MALIA A. KEKAI 10550 Deputy Corporation Counsel Office of the Corporation Counsel County of Hawai‘i 101 Aupuni Street, Suite 325 Hilo, HI 96720 Telephone: (808)961-8251 Facsimile: (808)961-8622 E-mail: Malia.Kekai@hawaiicounty.gov Attorney for Appellee DIRECTOR OF THE DEPARTMENT OF ENVIROMENTAL MANAGEMENT, COUNTY OF HAWAI‘I BEFORE THE ENVIROMENTAL MANAGEMENT COMMISSION COUNTY OF HAWAI‘I In the Matter of the Appeal of Kai Ala Partners LLC Appellant, and Ramzi Mansour, Director, Department of Environmental Management, County of Hawai‘i Appellee.
APPELLEE’S WITNESS AND EXHIBIT LIST; CERTIFICATE OF SERVICE Hearing: Date: December 29, 2021 Time: 10:00 a.m.
APPELLEE’S WITNESS AND EXHIBIT LIST
Comes now the DIRECTOR OF THE DEPARTMENT OF ENVIRONMENTAL
MANAGEMENT, COUNTY OF HAWAI‘I, ("Appellee”), by and through his attorney, MALIA
A. KEKAI, Deputy Corporation Counsel, and hereby submits the Witness and Exhibit List in the
above-captioned matter.
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I. WITNESSES
Appellee intends to call the following witnesses:
1. Ramzi Mansour, Director, Department of Environmental Management
2. Toni Nakatani, Former Inspector, Department of Environmental Management
Wastewater Division
3. Robin Bauman, Business Management Department of Environmental
Management
II. EXHIBIT LIST
EXHIBIT INDEX
EXHIBIT DATE DESCRIPTION PAGES
A Relevant Hawai‘i County Code Sections 1
B Hawai‘i County Code Section 21-36.1, showing
sewer rate changes for the last 3 years 1
C 05/06/1998 Sewer Connection Card 1
D 12/20/2021 Inspector Toni Nakatani Direct Testimony
E 05/12/2021 Pictures of structures on Subject Property taken by
Inspector Nakatani 1
F 06/10/2021 Letter from Director Mansour to Richard
Henderson 2
G 12/20/2021 Director Ramzi Mansour Direct Testimony
H 10/12/2005
Bill Reprint showing 2 units,
which is the first bill that went out after DEM
converted to a new billing system.
1
I 03/15/2019 Notice of Residential Sewer Rate Change 1
J 04/01/2020 Notice of Residential Sewer Rate Change 1
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K 04/15/2021 Notice of Residential Sewer Rate Change 1
L 12/20/2021 Business Manager Robin Bauman Direct
Testimony
M 2019 to
Present Bill Reprints from 2019 to Present 15
Appellee reserves the right to amend this Witness and Exhibit List to include additional
witnesses and exhibits, including rebuttal witnesses and exhibits, and issues that may be
identified in further discovery at the Environmental Management Commission hearing.
DATED: Hilo, Hawaii, December 20, 2021.
Ramzi Mansour, Director Department of Environmental Management, Appellee
By__/s/ Malia A. Kekai_________
MALIA A. KEKAI
Deputy Corporation Counsel
Attorney for Appellee
BEFORE THE ENVIRONMENTAL MANAGEMENT COMMISSION COUNTY OF HAWAI‘I In the Matter of the Appeal of Kai Ala Partners LLC Appellant, and Ramzi Mansour, Director, Department of Environmental Management, County of Hawai‘i Appellee.
CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a copy of the APPELLEE’S WITNESS AND
EXHIBIT LIST was served upon the parties below via email on December 20, 2021:
Ritchie Henderson & Richard Henderson, Managing Members:
Richard.henderson@rinvest.com
Ritchie.henderson@rinvest.com
Representatives for Applicant/Appellant
KAI ALA PARTNERS LLC
Keyra K. Wong keyra.wong@hawaiicounty.gov
Deputy Corporation Counsel:
Attorney for the Appellee
ENVIRONMENTAL MANAGEMENT COMMISSION
Peter Sur Peter.Sur@hawaiicounty.gov
Secretary for Environmental Management Commission:
Dated: Hilo, Hawai‘i, December 20, 2021.
/s/ Malia A. Kekai
MALIA A. KEKAI
Deputy Corporation Counsel
Attorney for Appellee RAMZI I. MANSOUR, DIRECTOR OF THE DEPARTMENT OF ENVIRONMENTAL MANAGEMENT