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CLARE E. CONNORS 7936 Attorney General of Hawaii CARON M. INAGAKI 3835 JOHN M. CREGOR, JR. 3521 Deputy Attomeys General Department of the Attorney General, State of Hawaii 425 Queen Street Honolulu, Hawaii 96813 Telephone: (808) 586-1494 Email: John M.Cregor@hawaii.gov Attorneys for Defendants CLARE E. CONNORS, Attorney General of Hawaii, and AL CUMMINGS, State Sheriff (In Their Official Capacities) IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF HAWAII ANDREW NAMIKI ROBERTS, | CIVIL NO. CV18-00125 HG-RT Plaintiff, DEFENDANTS CLARE E. CONNORS AND AL CUMMINGS’ a RESPONSE TO PLAINTIFF'S FIRST SET OF REQUESTS FOR SUSAN BALLARD, in her Official INTERROGATORIES TO. Capacity as the Chief of Police of DEFENDANTS, DATED Honolulu County, and RUSSELL SEPTEMBER 27, 2018 SUZUKI, in his capacity as the Attorney General of the State of Hawaii, and AL CUMMINGS, in his Official Capacity as the State Sheriff Division Administrator, Defendants. 7511301 DEFENDANTS CLARE E. CONNORS AND AL CUMMINGS’ RESPONSE TO PLAINTIFF'S FIRST SET OF REQUESTS FOR INTERROGATORIES TO DEFENDANTS, DATED SEPTEMBER 27, 2018 CLARE E. CONNORS, Attorney General of Hawaii, and AL CUMMINGS, Sheriff Division Administrator (In Their Official Capacities) (hereinafter “Defendants”), by and through their counsel, Clare E. Connors, Attorney General of Hawaii, Caron M. Inagaki and John M. Cregor, Jr., Deputy Attomeys General, hereby respond to Plaintiff's First Set of Requests for Interrogatories to Defendants, dated September 27, 2018. GENERAL RESPONSES AND OBJECTIONS 1. The Defendants object to all the interrogatories in the Interrogatories to Defendants to the extent that they ask for the disclosure of privileged communications, information that is protected work product, and information concerning documents and tangible things prepared in anticipation of litigation or trial. 2. The Defendants object to each request to the extent that it is unreasonably burdensome, oppressive or vexatious, in that the information so acquired would be of little or no relevance to the issues in this case, and/or would place an unreasonable and oppressive burden on the Defendants in expenditure of time, costs, and money. 7511301 3. The Defendants object to those interrogatories that are so broad, uncertain, and unintelligible that the Defendants cannot determine the nature of the response sought, and the Defendants therefore are unable to respond. 4. The Defendants do not concede that any of their responses will be admis ible evidence at trial. Further, the Defendants do not waive any objections, whether or not stated herein, to use such answers at trial. 5. The Defendants state that discovery, investigation, and trial preparation are ongoing and have not been completed. Any and all answers to the First Set of Requests for Interrogatories to Defendants, dated September 27, 2018 are based only on information available to the Defendants at the time that their responses and objections were prepared. 6. All specific responses and objections are made without waiving any of the general responses and objections. 7. Without waiving any of the foregoing objections, which the Defendants incorporate by reference in response and/or objection to each of the following individual requests as if fully set forth therein, the Defendants further respond and object to the individual requests herein. Ht u 7511301