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CLARE E. CONNORS 7036 Attorney General of Hawaii CARON M. INAGAKI 3835 JOHN M. CREGOR, JR. 3521 Deputy Attorneys 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’ vs. RESPONSE TO PLAINTIFF'S REQUEST FOR PRODUCTION OF SUSAN BALLARD, in her Official DOCUMENTS Capacity as the Chief of Police of Honolulu County, and RUSSELL 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. 751129.1 DEFENDANTS CLARE E. CONNORS AND AL CUMMINGS’ RESPONSE TO PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUME! 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 Request for Production of Documents, dated September 27, 2018. GENERAL RESPONSES AND OBJECTIONS 1. Defendants object to each request for production of documents to the extent that it requests the production of documents that are immaterial and irrelevant to the subject matter of this action. 2. Defendants object to each request for production of documents to the extent that it requests the production of documents that are within the attorney- client privilege. 3. Defendants object to each request for production of documents to the extent that it requests the production of documents that are not discoverable by reason of work product. 4, Defendants object to each request for production of documents 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 7511291 2 action, and/or would place an unreasonable and oppressive burden on the Defendants in expenditure of time and money. 5. Defendants objects to each request for production of documents that is so broad, uncertain and unintelligible that the Defendants cannot determine the nature of the documents sought, and to which the Defendants, therefore, are unable to respond. 6. Defendants object to each request for production of documents to the extent that it requests the production of documents that are as easily available to Plaintiff. 7. Defendants object to each request for production of documents to the extent that it requests the production of documents for which the required good cause or substantial need, as dictated by applicable statutes, court rules and case Jaw, has not been shown. 8. All specific responses and objects below are made without waiving any of these general responses and objections. DATED: Honolulu, Hawaii, June 12, 2019. /_ John gor JOHN M. CREGOR, JR. Deputy Attorney General Attorney for Defendants CLARE E. CONNORS and AL. CUMMINGS, In Their Official Capacities 7511291 3