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.
751129.1DEFENDANTS 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 2action, 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