Motion For PI Complete

Case 1:12-cv-00469-JMS-RLP Document 7-1 Filed 08/21/12 Page 1 of 17 PageID #:
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RICHARD L HOLCOMB (HI Bar No. 9177)
BRIAN J BRAZIER (HI Bar No. 9343) (Of Counsel)
Holcomb Law, A Limited Liability Law Corporation
1136 Union Mall, Suite # 808
Honolulu, HI 96813
Telephone: (808) 545-4040
Facs1mile: (808) 356-1954
Email:
Email: brianbrazier gmail.com
ALAN BECK (HI Bar No. 9145)
Attorney at Law
4 780 Governor Drive
San Diego, California 92122
Tele_r,hone: (808) 295-6733
Emall: ngord2000@yahoo.com
Attorneys for Plaintiffs
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF HAW All
Hawaii Defense Foundation,
Christopher Baker,
and Derek Scammon
Plaintiffs,
vs.
City and County of Honolulu;
Anorew Lum, in his personal and
official capacity;
John Does 1-10 in their personal and
official capacities.
Defendants.
CASE NO.
MEMORANDUM IN SUPPORT OF
MOTION FOR PRELIMINARY
INJUNCTION
60
I. Introduction
The First Amendment of the United States protects the "freedom of
speech". U.S. Const. amend I. Political speech is at the core of that protected
by the First Amendment. NewYork Times, Co. v. Sullivan, 376 U.S. 254
(1964). The United States Supreme Court applied the First Amendment's
free of speech and freedom of press provisions to the states in 1925. Gitlow
v. New York, 268 U.S. 652 (1925).
The City and County of Honolulu, through its subdivision the
Honolulu Police Department ("HPD") and its agents, operate an official
social media page through the website "Facebook.com." The page states that
it is the "official Facebook page of the Honolulu Police Department."
1
The
site purports to be "a forum open to the public."
2
A forum is by definition a
place for discussion. However, the administrators of this public forum
censored comments left by the Plaintiffs by removing those comments from
the website. Plaintiffs and other members of Hawaii Defense Foundation
("HDF") were subsequently banned from any participation in the forum.
Plaintiffs seek an injunction restoring their deleted posts, permitting
Plaintiffs to participate and advance their political views in the forum
1
Exhibit One, Screen Shot from HPD Facebook page.
2
Exhibit Two, HPD Facebook page "General Information."
1
61
discussions, and prohibiting Defendants, their officers, agents, servants,
employees, and all persons in active concert or participation with them who
receive notice of the injunction from banning not only Plaintiffs but any
person for political speech made on the Honolulu Police Department's
facebook page and/or removing posts based on their political content.
II. STANDING
A. Plaintiffs have standing.
As a preliminary matter, the Plaintiffs have standing. To satisfy
standing requirements, a plaintiff must show: "(1) it has suffered an 'injury
in fact' that is (a) concrete and particularized and (b) actual or imminent
conjectural or hypothetical; (2) the injury is fairly traceable to the challenged
action of the defendant; and (3) it is likely, as opposed to merely speculative,
that the injury will be redressed by a favorable decision." Friends of the
Earth, Inc. v. Laidlaw Envtl. Servs. (TOC), Inc., 528 U.S. 167, 180-81
(2000) (quoting Lujan v. Defenders of Wildfire, 504 U.S. 555, 560-61
(1992)).
In this case, Plaintiffs' comments were deleted from the public forum
(i.e., HPD's Facebook page) without cause and Plaintiffs were banned from
all further participation in the forum discussion. Thus, through Defendants'
actions and/or omissions, Plaintiffs' political speech has been censored from
2
62
a public forum and Plaintiffs have no means of expressing their particular
political viewpoints in this particular forum. In contrast, other members of
the community continue to enjoy the use of this forum. If Plaintiffs were
given the opportunity they would resume commenting on the HPD Facebook
page in order to express opinions about issues brought up by or related to
HPD.
B. Hawaii Defense Foundation has Organizational Standing
The United States Supreme Court has held that an organization or
association "has standing to bring suit on behalf of its members when: (a) its
members would otherwise have standing to sue in their own right; (b) the
interests it seeks to protect are germane to the organization's purpose; and
(c) neither the claim asserted, nor the relief requested, requires the
participation of individual members in the lawsuit." Hunt v. Washington
State Apple Advertising Comm., 432 U.S. 333, 343 (1977). Here, HDF has
standing.
First, all Plaintiffs are members of the Hawaii Defense Foundation
("HDF").
3
Each clearly has standing as discussed above; and the first prong
of the Hunt test is satisfied. Second, the purpose of HDF is to "to defend
3
Declarations of Plaintiffs Christopher Baker and Derek Scammon, attached
as Exhibits Three and Four.
3
63
and protect the civil rights of arms owners. "
4
As this lawsuit directly
challenges government action that violates HDF members' civil rights, the
second prong of the Hunt test is also satisfied. Third, the relief sought does
not require the participation of any HDF members. Therefore, HDF clearly
has organizational standing.
III. THE PRELIMINARY INJUNCTION SHOULD ISSUE
The proper legal standard for preliminary injunctive relief requires the
moving party to demonstrate "that he is likely to succeed on the merits, that
he is likely to suffer irreparable harm in the absence of preliminary relief,
that the balance of equities tips in his favor, and that an injunction is in the
public interest." Winter v. Natural Res. Def Council, Inc., 55 U.S. 7, 19,
129 S.Ct. 365, 374, 172 L.Ed.2d 249 (2008).
A. Plaintiffs are likely to succeed on the merits.
Plaintiffs' First Amendment Rights have been violated.
Limited or designated public forums are defined as an outlet "which
the state has opened for use by the public as a place for expressive activity"
and are treated substantially the same as traditional public forums. Perry
Local Educators' Association, 460 U.S. 37, 45 (1983). This public forum
need not be a physical place. For example, in Rosenberger v. Rector and
4
Exhibit Five, HDF Charter.
4
64
Visitors ofthe University of Virginia, 515 U.S. 819 (1995), the Court found
that Virginia had created a limited public forum when it established a fund
that would cover the cost of publications by eligible student groups and that
denying such funding to a student group, which wished to publish a
Christian newspaper, violated the First Amendment.
Here, in creating an official Facebook page, Defendants have also
created (at the very least) a designated public forum. There is no question as
to whether Defendants intended the official HPD Facebook page be a public
forum. Indeed, on the page itself, Defendants have so designated the page
stating that this .is "a forum open to the public."
5
Defendants have only
warned that "obscene, sexually explicit, racially derogatory, defamatory
comments or labels, solicitations or advertisements, or comments suggesting
or encouraging illegal activities" might be removed from the forum.
6
There
is no suggestion that even offending participants would be banned from
participation even when those rules were violated.
7
While the Defendants' Facebook page is clearly not a physical
location, the facts of Rosenberger are closely analogous to those of this case.
See Id. Defendants have created an outlet for expressing viewpoints just as
5
Exhibit Two.
6
Exhibit Two.
7
See Exhibit Two.
5
65
that created by the University of Virginia. Id. Defendants have denied
participation in that particular outlet to citizens who have expressed
protected political speech based solely on Defendants' disagreement with
that protected speech. The only difference is that in Rosenberger, supra.,
the University of Virginia had a policy in place preventing it from
supporting a particular (in that case, religious) viewpoint. !d. Here,
although reliance on a policy would be no justification of the Defendants'
conduct, there is no policy whatsoever. Defendants have so admitted in
response to a Uniform Information Practices Act request.
8
Indeed, the Facebook page is more akin to a traditional forum than
that of the fund at issue in Rosenburger. As such the Facebook page must
conform to the requirements of a public forum. Specifically, content-based
restrictions that apply to certain viewpoints but not others face the highest
level of scrutiny. Legal Services Corp. v. Velazquez, 531 U.S. 535 (2001).
Here, plaintiffs were banned from the Facebook page based upon the
political content of their posts. Accordingly, strict scrutiny applies. To meet
strict scrutiny, censorship must be justified by a compelling governmental
interest, narrowly tailored, and by the least restrictive method to achieve the
government interest. See e.g., Austin v. Michigan Chamber of Commerce,
8
Exhibit Six, Response to Information Practices Act Request.
6
66
494 U.S. 652, 655 (1990); Boos v. Barry, 485 U.S. 312, 334 (1988)
(plurality); see also Burson v. Freeman, 504 U.S. 191, 198 (1992)
(plurality); Board of Airport Comm'rs v. Jews for Jesus, Inc., 482 U.S. 569,
573 (1987); Cornelius v. NAACP Legal Defense and Educ. Fund, Inc., 473
U.S. 788, 800 (1985); United States v. Grace, 461 U.S. 171, 177 (1983);
Perry Educ. Ass'n v. Perry Local Educators' Ass'n, 460 U.S. 37,45 (1983).
It is difficult to imagine circumstances in which it would be
permissible to limit a public forum to all areas of speech except those critical
of the sponsoring government agency. Any argument suggesting that the
government has a compelling interest in preventing criticism of a governing
regime should be summarily dismissed as completely inapposite to the
freedom of all Americans.
Yet, in this case, Defendants simply removed critical comments from
the forum altogether. To add insult to injury, Defendants then banned
Plaintiffs from further participation in the forum, the least narrowly tailored
action imaginable.
9
This action was taken without articulating any
compelling reason for curbing the political speech. Moreover, as noted
9
Plaintiff Scammon has since been reinstated. However, his comments
remain removed. Plaintiff Baker remains banned from participation. Both
Plaintiffs' speech has been chilled. Plaintiff Scammon joins numerous
members of organizational Plaintiff Hawaii Defense Foundation in their fear
that the exercise of free speech may result in being banned from further
participation in the forum.
7
67
above, Defendants have admitted the complete absence of any articulated
policies as to how they administer the site.
10
Plaintiffs do not dispute that Defendants can restrict the content of the
comments insofar as the parameters of the page's purpose allow, 1.e.
discussing the HPD and subjects tangentially related to it. Indeed, the
Face book page enumerates certain types of speech that it does not allow, e.g.
unprotected speech such as that inciting illegal activity. I I Thus, the
Defendants have designated this particular forum to invite to public
discussion on all topics other than those specifically enumerated.
Importantly, the rules do not disallow political speech.
12
Following the holding in Perry, supra., banning users for political
speech and/or eliminating posts is clearly unconstitutional. "The
Constitution forbids a state to enforce certain exclusions from a forum
generally open to the public even if it was not required to create the forum in
the first place." Widmar v. Vincent, 454 U.S. 263_(1981) (university meeting
facilities); City of Madison Joint School District v. Wisconsin Employment
Relations Comm'n, 429 U.S. 167_(1976) (school board meeting);
Southeastern Promotions, Ltd. v. Conrad, 420 U.S. 546 (1975) (municipal
10
Exhibit Six.
I
1
Exhibit Two.
12
Exhibit Two.
8
68
theater); Perry Educ. Ass'n 460 U.S. 37, 46 (1983). Although a State is not
required to indefinitely retain the open character of the forum, so long as it
does, it is bound by the same standards that apply in a traditional public
forum.
Instead, the HPD administrators arbitrarily and capriciously removed
Plaintiffs' posts, which were critical of the HPD, from the page. Then,
presumably to prevent any further posting of protected political speech,
Plaintiffs have been subjected to an outright ban on any further participation
in the forum discussions while other members of the public remain invited to
do so. Certainly, no narrowly tailored prohibitions are in place to justify
these actions and this censorship effectuates no compelling state interests.
Plaintiffs' constitutional rights have been and continue to be violated.
The administration of the Facebook page violates due process.
The Due Process Clause states "nor shall any State deprive any person
of life, liberty, or property without due process of law." This requires
procedural safeguards to accompany substantive choices. Const. amend.
XIV. Plaintiffs' comments were censored and their further participation
forbidden without any explanation.
When analyzing procedural due process, the court should apply the
three factor test articulated by the Supreme Com1 in Mathews v. Eldridge,
9
69
424 U.S. 319 (1976). There, the Supreme Court stated that in order to
determine the adequacy of due process, the following should be considered:
First, "[t]he private interest that will be affected by the official action;
second, the risk of an erroneous deprivation of such interest through the
procedures used, and the probable value, if any, of additional or substitute
procedural safeguards; and, finally, the Government's interest, including the
function involved and the fiscal and administrative burdens that the
additional or substitute procedural requirement would entail." Id at 3 21.
Here, the interest affected is Plaintiffs' fundamental right to free
speech. The risk of erroneous deprivation is very high as it appears that only
one person arbitrarily makes the decision, without explanation, and with no
means to have that decision reviewed. Indeed, these Plaintiffs have already
suffered such erroneous deprivation.
The administrative burden imposed on Defendant( s) would be, at
worst, minimal. In fact, unless the governing rules of the forum are changed,
the appropriate action that the administrator( s) should take is none at all -
unless and until unprotected speech was posted at which time, according to
the website itself, Defendants would be expected to take administrative
action. Further, the rules could be amended to notify the public that
unprotected speech would be removed, the offending participant could be
10
70
banned from further participation, and, if desirable, the forum could be
limited to specific topical subjects. The promulgation of any such rules
would alleviate any additional burden, no matter how minimal, that is
created by demanding that the HPD respect the public's First Amendment
Rights. Indeed, once the rules were promulgated, the Facebook
administrator would do no more than they are currently doing.
The only foreseeable additional burden that should be imposed is
affording aggrieved citizens some form of review pertaining to their
removed post(s). Certainly, citizens should be notified and afforded some
meaningful opportunity to be heard before being prohibited from
participating in the public discussion. While it is highly doubtful that the
number of citizens aggrieved by such action would overwhelm
administrators, even if it did require additional or even substantial effort on
the part of HPD, such is the cost due process requires.
For these reasons, Plaintiffs have a very high likelihood of success on
the merits of the case.
B. Plaintiffs are harmed irreparably.
Plaintiffs will suffer irreparable harm to their liberty if not granted a
preliminary injunction. The United Supreme Court has long held that "the
loss of First Amendment freedoms, for even minimal periods of time,
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unquestionably constitutes irreparable injury." Elrod v. Burns, 427 U.S. 347
(1976). Indeed, when liberties are infringed, irreparable injury is presumed.
llA Charles Alan Wright et al., Federal Practice & Procedure 2948.1 (2d
ed. 1995) ("When an alleged deprivation of a constitutional right is involved,
most courts hold that no further showing of irreparable injury is
necessary."). Here, Plaintiffs have been and are currently being deprived of
their First Amendment right to free speech in a public forum. The law is
clear. Plaintiffs have suffered irreparable harm.
This factor unmistakably weighs heavily in favor of the issuance of
the requested injunction.
C. The Balance of Equities Mandates Relief.
Plaintiffs suffered the deprivation of a fundamental right. If this
motion is not granted they will continue to suffer. Yet, it is not only
Plaintiffs' liberty that is affected. Anyone wishing to exercise his or her
First Amendment rights in Hawai 'i is subject to arbitrary prohibitions from
doing so. Thus, this case is analogous to Klein v. City of San Clemente, 584
F.3d 1196 (9th Cir. 2009).
In Klein the plaintiffs challenged a prohibition of their fundamental
right to free speech. Id. The Court ruled that because the state action
affected "anyone seeking to express their views in this manner in the City of
12
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San Clemente[,] the balance of equities and the public interest thus tip
sharply in favor of enjoining the ordinance." Id. at 1208. Similarly,
the policies sub judice, affect anyone who wishes to exercise their
fundamental right of free speech on Defendants' Face book page.
13
Regardless of whether this Court grants injunctive relief, Plaintiffs
will have spent a great deal of time deprived of their First Amendment rights
in this particular public forum. No one has the ability to tum back the clock,
only to prevent continued and future deprivation. Therefore, the burden of
denial of an injunction would be great on the plaintiff. On the other hand, as
stated above, the State of Hawai'i suffers no harm by enjoining the
aforementioned conduct and simply instructing the administrator of the
Facebook page to abide by constitutional guidelines- something Defendants
13
Notably, the facts of Klein presented an actual interest other than avoiding
public criticism. Specifically, the Plaintiff was attaching fliers to parked
cars. Id. The government argued that , in determining the balance of
equities, "the Court need look no further than the Ordinance itself to find
evidence of the City's interests and goals," as "the City's interest in curbing
litter is evidenced by the explicit title of the ordinance[,] .. . the 'San
Clemente Anti-Litter Ordinance."' Id. at 1203. However, the Court found
that the interest in curbing litter was insufficient to outweigh the plaintiffs
freedom of speech and granted the Plaintiff a preliminary injunction. Id. In
the event that these Defendants invent some argument that they have an
interest in "curbing the litter" of critical political speech on the page, this
argument should fail as the curbing of all litter (and not just that selected for
its content) was squarely rejected in Klein. Notably, Defendants do not
delete such "litter" that is supportive of the HPD. Exhibit Seven, Selected
Posts. Further, and more obviously, this "litter" does not pollute the streets.
13
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should have done all along. Therefore, the balance of hardships weighs
heavily in the Plaintiff's favor.
D. It serves the public interest to grant relief.
It is in the public interest to issue a preliminary injunction in this
matter. The Ninth Circuit has stated, "all citizens have a stake in upholding
the Constitution" and have "concerns [that] are implicated when a
constitutional right has been violated." Preminger v. Principi, 422 F.3d 815,
826 (9th Cir. 2005). A preliminary injunction vindicating Plaintiffs and
other similarly situated citizens' fundamental First Amendment rights would
advance the shared interest of all citizens in enforcing the Constitution's
guarantees and reinforce this "Nation's basic commitment to foster the
dignity and well-being of all persons within its borders." Goldberg v. Kelly,
397 u.s. 254, 264-65 (1970).
Whenever the government is able to control the appearance of public
sentiment it is an insidious encroachment on American free speech. Indeed,
in this case, government actors have quashed political dissent. This action
epitomizes the very reasons our law has consistently rejected government
censorship. If the government is able to quell, whether by deleting posts or
through the threat of prosecution, any opinions with which it disagrees, our
very democracy is at risk. Since public discourse is the cornerstone of the
14
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means by which Americans have chosen to govern themselves, it clearly is
in the public interest to prevent the government from censoring such
discourse, be it in electronic forums or otherwise.
III. CONCLUSION
Plaintiffs are entitled to the requested relief. Plaintiffs are likely to
succeed on the merits. Plaintiffs have and will continue to suffer irreparable
harm in the absence of preliminary relief. This harm includes not only a
deprivation of liberty but also a deprivation of income. The balance of
equities tips in his favor. In addition to Plaintiffs, all of Hawaii's citizens
who use the HPD's Facebook page are affected. Thus, the injunction is also
in the public interest.
For any and all of the reasons stated above, Plaintiffs request this
Court issue an order:
compelling Defendants to restore Plaintiffs' deleted posts;
permitting Plaintiffs to participate in the forum;
prohibiting Defendants, their officers, agents, servants,
employees, and all persons in active concert or participation
with them who receive notice of the injunction from banning
persons for political speech those persons have caused to appear
on the Honolulu Police Department's Facebook page and/or
removing posts based on their political content.
15
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DATED: Honolulu, Hawai'i; August 20, 2012.
16
sf Richard L. Holcomb
Richard L. Holcomb
Brian Brazier
Attorneys for Plaintiffs
s/AlanBeck
Alan Beck
Attorney for Plaintiffs
Case 1:12-cv-00469-JMS-RLP Document 7-2 Filed 08/21/12 Page 1 of 1 PageID #: 76
Exhibit One
Honolulu Police Department (Official Site)
This 1S the off,ca! Facebook page of the Hono
1
u!u Poke
01.?pcutrnent
,5,477
Honolulu
"liked , *
Exhibit Two
General Information
e Honolulu Police Depa nt's Offlcla page on Facebook!
Here you d the rnost recent departmental actrvrt:ies, ne'NS stories,
videos, photos, and distributed by the Honolulu Po Departrnent's
Pub Information Office.
If you need an official source for inforrnation about
Departrnent (HPD) please visit our 'Nebstte at
\Nh this is a forurn open to the public, be dful that access is available for
those 13+. 'vVe ask that you folio',\' our posting guide es belmv; non-
compliance resutt in your message be1ng removed.
No obscenities, explicit or derogatoty language, nor
defamatory comments or labels to'Nard anyone or organization are allo'Ned.
No unauthorized solicrt:ations or advertisements are aliO'Ned.
No cornments suggesting or encouraging illegal actr1ities are allowed.
Persona responsibilrty is assurned by the user for comments, username, and
any Information placed on is page by the user.
The HPD rnonitors this Facebook site acti.rety du g norn1a business hours
from 0745-1630 hrs. fv1onday-Friday, Ha'Naii Standard Time (Ha'Na State and
Federal Holidays are observed). The HPD reserves the right to remove any
post or cornment on this srt:e.
Exhibit Three
SUPPORTING DECLARATION OF CHRISTOPHER BAKER
1. My name is Christopher Baker. I am a Plaintiff in the above-styled
case.
2. I reside in the State ofHawai'i.
3. I twenty-seven years old and I am a citizen of the United States.
4. I am the acting President and co-founder of the Director of the
Hawaii Defense Foundation.
5. I am an arms owner.
6. During the period of January 1 ih to the 28th, I made a variety of
"wall" posts on the Official Facebook Fan page of the Honolulu Police Department
(http://www.fb.com/honolulu.police) for the purpose of political speech and to
educate others on the topics of self-defense and personal safety; shortly after
posting, my posts were removed from the "wall" of the Honolulu Police Page.
7. After the initial posts were removed, I made additional comments and
posts in protest of the Police Department's actions in deleting my expressive
conduct. This post, just like the others, was removed.
8. After making numerous postings, I discovered that I was banned from
commenting, posting, or significantly participating in the open public forum on the
Honolulu Police Department's Official Facebook Fan page.
Exhibit Three
9. Additionally, all of my comments on these posts were censored and
removed. The Honolulu Police Department publicly stated that they deleted and
removed my posts.
10. I did not delete or remove any posts made by myself on the Honolulu
Police Department's Official Facebook Fan page.
11. I did not ask or communicate that I wanted my posts to be removed.
12. I am currently still unable to participate on the Honolulu Police
Department's Face book Fan page.
13. If the ban were removed, I would resume posting, commenting,
sharing, and otherwise participating in the public discussion and debate on the
Honolulu Police Department's Official Facebook Fan page through all available
means, but I am unable to do so because of the ban.
I, Christopher Baker, I declare under penalty of perjury that the foregoing is
true and correct. And, pursuant to the provisions of 28 U.S.C. 1746 and Hawai 'i
law, that all the statements made in this declaration are true to the best of my
information, knowledge and belief.
Dated: Honolulu, Hawai'i, August 15th, 2012.
~ - ~ l ~ .
Christopher Baker
'L
Exhibit Four
SUPPORTING DECLARATION OF DEREK SCAMMON
1. My name is Derek Scammon. I am a Plaintiff in the above-styled
case.
2. I reside in the State ofHawai 'i.
3. I am an American citizen.
4. I am a member and a Director of the Hawaii Defense Foundation.
5. I am an arms owner.
6. On or about January 18th, 2012, I made a "wall" post on the Official
Facebook Fan page of the Honolulu Police Department
(http://www.fb.com/honolulu.police) for the purpose of political speech and to
educate others on the topic of self-defense; shortly after posting, my post was
removed from the "wall" of the Honolulu Police Page.
7. Around the 18th of January, 2012, I made an additional post in protest
of the Police Department's continuous violation of civil rights. This post, just like
the others, was removed.
8. Soon after making my posts in January of 2012, I discovered that I
was banned from commenting, posting, or significantly participating in the open
public forum on the Honolulu Police Department's Official Facebook Fan page.
9. Additionally, all of my comments on these posts were censored and
removed.
Exhibit Four
10. I did not delete or remove any posts made by myself on the Honolulu
Police Department's Official Facebook Fan page.
11. I did not ask or otherwise communicate that I wanted my posts to be
removed.
I, Derek Scammon, I declare under penalty of perjury that the foregoing is true and
correct. And, pursuant to the provisions of 28 U.S.C. 1746 and Hawai 'i law, that
all the statements made in this declaration are true to the best of my information,
knowledge and belief.
Dated: Honolulu, Hawai'i, August 15th, 2012.
1.
;;,
Exhibit Five
FORM DNPS
7/2008
I
t '
FILED 02/11/2011 08:57AM
Business Registration Division
DEPT. OF COMMERCE AND
CONSUMER AFFAIRS
STATE OF HAWAII
DEPARTMENT. OF COMMERCE AND CONSUMER AFFAIRS
Business Registration Division
I limO IIIIU
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Stale of Hawaii
335 Merchant Street
Mailing Address: P.O. Box 40, Honolulu, Hawal196810
Phone No. (808) 586-2127
23153302
AMENDED
i:( . :''' . ;' : .'"'.
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The undersigned, duly authorized of the
khehded' \inJ Restated Articles of Incorporation,

certify follows: l / - >\. I
1. The name of the corpomtliln Is; i f f
.t " ..
"awa,\ : f.o\lnua:-hon - ,
Total Nl.lllberof Memberships
Total Number at Votes Number of Votes cast Number of Votes cast
Designation
(votes) oulstandlng
En:'ed to be cast
by each class by each class
Of members each Class For Amendment Aaalnst Amendment
N OR
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0 by written of the members holding at least eighty per cent of vo11ng power.
OR
Oj by a sufficient vote of the Board of Olrectors or fncorpaffltors because member approval was not required.
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4. Chack one:
D The written approval ofa SJ)eclffed person or persons named In the at.lcles of Incorporation was obtained.
C.B.
lXI The written approval of a specified person or persons Is not required.
s. Th6 attached Amended and Restated Articles of Incorporation supersedes the orlgfnal Articles of Incorporation and all
amendments thereto.
The unclerslgned certifies under the penalties of Section 4140-12, Hawan Revised Statutes, that the undersigned has read the
above statements, 1/we are authorf%ed to make this change, and that the statements are true and correct.
Signed this day of U. &g '-1 , '2. \\
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Ck v'\kpltv".6o..V..e../ / rg.6idecl:

CL.-;s 2/. r
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Namot 1!.1'\llo)

SEE INSiRUCTIONS ON REVERSE SIDE. The arllcles mus1 be signed by at least one ofllcer of the corporation.
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Exhibit Five
I HEREBY CERTIFY that this is a true and
correct: copy of the official record(s) of
the B u ~ i n e s s Registration Division.
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Exhibit Five
Article I
Name and Address of Corporation
Tht: nome of this corponllinn.is: Hawaii Defense Fnundtuiun.
Article Jl
Location of Principal Office
The mniling address l'fthe corporations initial pi-incipal uflicc is:
3308 Moreell Street. Honolulu. Hawaii 9681 &
1
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Article Ill
..
....
Agent
The corporation shall have and continuously maintain in the State of Hawaii u registerl.!d
agent who shall have a business address in this state. The agent muy be an individual who
resides in this stale. a domestic entity or a foreign entity authorized to transact husincss in
this state.
A.)
B.)
The name (and state or country of incorporation. formation of organization. if
applicable) of the corporations registered agent in Hawaii is:
Christopher Henn Baker
The street address of the place of business ofthe person in the State ofHawaii to
which service of process and other notice and documents being served on or sent
to the entity represented by it may be delivered to is:
3308 Moreell Street. Honolulu, Hawaii 96818
Article IV
Statement of Purpose
The purposes for which this corporation is organizt!d
t. To defend and protect the civil righ\s of am1s owners:
2. To promote. advance. and encourage firearms safety;
3. To educate individuals. including the youth of United States, with respect to
firearms and firearm history. safety. and marksmanship. as well as with respect to other
subjects that are importance to the wellbeing of the general public;
llnwuil Fountlnlitm ul'lncurpvrutillll l'tlgc I
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Exhibit Five
Tn conduct rcscun:h in the furtheruncc ur impruvcd lircurms and
marksmanship facilities and techniques:
5. To support the w.:tivities of the National ri Oc Associution or Americu nr nthcr
non-profit organizations. but only tu the extent thut such activities ore in the furtherance
of charitable. educntinnul. or schmtitic purposes withh1 the mconing. of section 50 I (c}(3)
of the Jntcmnl Revenue Codt'! or 1986. as amended. or uny similar provision subsequently
enacted.
6. To educate the public. luw enforcement. und gon:nuncnt entities on the
ownership. usc. constitutional rights. laws und regulations of am1s:
7. To engage in nny other activity that is incidental to. connected with. or in the
udvancemcnl of the foregoing purposes and that is emirdy within the scope of nllowable
purposes under 26 U.S.C. 501 (c) (3).
.--. -:-z--:;:...:,_.
A'rticle V
Names of Incorporators
The name(s) and address(es) of the incorporntor(s) of this corporation is/arc:
Christopher H. Baker
3308 Moreell Street
Honolu]u. Hawaii 96818
Sara L. Baker
3308 Moreell Street
Honolulu. Hawaii 96818
Article VI
Membership
The classes, rights, privileges, qualifications, and obligations of members of this
corpomtion are set forth in the fol1owing text. This corporation shall have multiple levels
of membership. Any person shall be qualified to become a member upon payment of the
initial dues and shall continue as member of their respective level upon paying the anmuil
dues ofthat membership class. The amount, method. and time of payment qf dues shall
be detennined. and may be changed
1
from time to time. by the board of directors.
Additional provisions specifying the rights. obligations. and class of members shall be
contained in the corporations bylaws pursuant to. and in accordance with. the laws of this
state.
Articles ol'lncorpunuilln
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Exhibit Five
Article VII
Number, Names, and Address of Initial Directors
ofinitiul directors of this corpomtions shull be rnur und th\! und
uddressi;!S of the initiul directors are as lbllo\\s:
1. Christopher Henry Baker
J308 rvtoreell Street
Honolulu. Hawuii 96818
2. Erica Castillo
3.
4.
3012 Huehue Lane
Kailua. Hawaii 96734
--- -- .- - ... ---
Dexter Carrasco
550 1-lakkauwila Stree\. Ste. 301
. Honolulu. Hnwaii 96813
Alex Europ!il
68-024 Apuhihi Street APT #512\V
Wnilua. Hawaii 96791
Article VIII
Duration of Corporation
The period of duration of this corporation is perpetual.
Article IX
Additional Pro,isions
The property of this company is irrevocably dedicated to the defense and protection of
arms owner's civil rights and education on firearn1 safety and self-defense. Upon
dissolution or winding up the corporation, its assets remaining after paymenl or
provision for paymenl of all debts and liabilities of this corporation shall be distributed
to a nonprofit fund. foundation or corporation which is organized and operated
exclusively for defense and protection of arms owners civil rights or education on
firearm safety or self-defense purposes. and which has established its ta-..-exempt status
under of the Internal Revt!nue Code.
No substun\ial part of the activities or this corporation shall consist of carrying on
propaganda. or otherwise attempting to influence legislation (except as otherwise
provided by Section 50 I (h) of the Internal Revenue Code). and this corporation shall not
participate in. or intervene in (including the publishing or distribution of statements). any
political campaign on be hal r of. or in opposition to, any candidate for public office.
llnwuii Delcn.'i<: Fnumlntion Artlch::s n!' lncorpnml kn
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Exhibit Five
No Part of the net earnings nr this shull inure to Lht: benefit o[ or be
distributubk to. its members. directors. nllicers. ur llther privnte persons. t.-xcept that this
corporution shall he authorized und t:mpnwcrcd to pay rcusonahle fbr
services rcndt:rcd nnd to mukc pnyments und distrihutions in furthcruncc or the purposes
set forth in these artides.
Notwithstanding any other provision or these articll-s. this corponniun shall not curry on
any other activities not pcnnitted to be carried on ( 1) hy a corporation exempt rrom
federal income tax under Secth,n 50 I (c)(J) of the lntt!rnal Revenue or (2) by a
corporation contributions to which are deductible under Section l70(c)(1) ofthc Intcmul
Revenue
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lluwuii Dd\ms.! l'oundution ul" lncnrp!11nliun
--I'-
TO:
FROM:
Exhibit Six
NOTICE TO REQUESTER
(Use multiple forms if necessary)
Daniel M. Gluck
ACLU ofHawaii, P.O. Box 3410
Honolulu, Hawaii 96801
Lynne Uyema on behalf of Louis M. Kealoha. Chief of Police
Honolulu Police Department, 801 S. Beretania Street
Honolulu, Hawaii 96813
Ph: 723-3848
(Agency/name & telephone number of contact person at agency)
DATE REQUEST RECEIVED:
DATE OF THIS NOTICE:
January 11. 2012 (modified by requester to January 18. 2012)
January 25. 2012
GOVERNMENT RECORDS YOU REQUESTED (attach copy of request or provide brief description below):
1. Please refer to attached copy of request
NOTICE IS PROVIDED TO YOU THAT YOUR REQUEST:
D Will be granted in its entirety.
D Cannot be granted because
D Agency does not maintain the records. Agency believed to maintain records: __
D Agency needs a further description or clarification of the records requested. Please contact the agency
and provide the following information: __
D Request requires agency to create a summary or compilation from records not readily retrievable.
~ Is denied in its entirety D Will be granted only as to certain parts
based upon the following exemption provided in HRS 92F-13 and/or 92F-22 and other laws cited below
(portions of records that agency will not disclose should be described in general terms).
RECORDS OR
INFORMATION WITHHELD
Proposed policies regarding
HPD's Facebook page
Records relating to any internal
correspondence regarding the
Removal of comments from HPD's
Facebook page
REQUESTER'S RESPONSWILITIES:
APPLICABLE
STATUTES
92F-13(3)
AGENCY
JUSTIFICATION
As of the date of this
response, HPD does not
have a policy regarding
Facebook. Any and all
proposed policies are in
draft form and have not
been formally adopted.
No records exist.
You are required to (1) pay any lawful fees assessed; (2) make any necessary arrangements with the agency to
inspect, copy or receive copies as instructed below; and (3) provide the agency any additional information requested.
If you do not comply with the requirements set forth in this notice within 20 business days after the postmark date of
this notice or the date the agency makes the records available, you will be presumed to have abandoned your request
and the agency shall have no further duty to process your request. Once the agency begins to process your request,
you may be liable for any fees incurred. If you wish to cancel or modify your request, you must advise the agency
upon receipt of this notice.
OIP 4 (rev. 7121 10)
Exhibit Six
METHOD & TIMING OF DISCLOSURE:
Records available for public access in their entireties must be disclosed within a reasonable time, not to exceed 10
business days, or after receipt of any prepayment required. Records not available in their entireties must be disclosed
within 5 business days of this notice or after receipt of any prepayment required. If incremental disclosure is
authorized by HAR 2-71-15, the first increment must be disclosed within 5 business days of this notice or after
receipt of any prepayment required.
Method of Disclosure:
D Inspection at the following location: __ .
D As requested, a copy of the record(s) will be provided in the following manner:
D Available for pick-up at the following location: __ .
D Will be mailed to you.
D Will be transmitted to you by other means requested: __ .
Timing of Disclosure: All records, or first increment where applicable, will be made available or provided to you:
D On __
D After prepayment of fees and costs of$ __ (50% of fees +100% of costs, as estimated below).
Payment may be made by cash or: D personal check D other
For incremental disclosures, each subsequent increment will be disclosed within 20 business days after:
D The prior increment (if one prepayment of fees is required and received).
D Receipt of each incremental prepayment required.
Disclosure is being made in increments because the records are voluminous and the following
extenuating circumstances exist:
D Agency must consult with another person to determine whether the record is exempt
from disclosure under HRS chapter 92F.
D Request requires extensive agency efforts to search, review, or segregate the records or
otherwise prepare the records for inspection or copying.
D Agency requires additional time to respond to the request in order to avoid an
unreasonable interference with its other statutory duties and functions.
D A natural disaster or other situation beyond agency's control prevents agency from
responding to the request within 10 business days.
ESTIMATED FEES & COSTS:
The agency is authorized to charge you certain fees and costs to process your request (even if no record is
subsequently found to exist), but must waive the first $30 in fees assessed for general requesters and the first $60 in
fees when the agency finds that the request made is in the public interest. See HAR 2-71-19, -31 and -32. The
agency may require prepayment of 50% of the total estimated fees and 100% of the total estimated costs prior to
processing your request. The following is the estimate of the fees and costs that the agency will charge you, with the
applicable waiver amount deducted:
Fees: Search Estimate of time to be spent: __ $ __
($2.50 for each 15-minute period)
Review & segregation Estimate of time to be spent: __ $ __
($5.00 for each 15-minute period)
Fees waived D general ($30) D public interest ($60) <$ __ >
$_
(Pursuant to HAR 2-7 -31(B) )
Total Estimated Fees: $_
OIP4(rev. 7/2/IU)
'L
Exhibit Six
Costs: Copying Estimate of# of pages to be copied: __ $_
(@ $ __ per page.)
Other $_
Total Estimated Costs: $_
For questions about this notice, please contact the person named above. Questions regarding compliance with the
UIPA may be directed to the Office ofinformation Practices at 808-586-1400 or oip@hawaii.gov.
OIP 4 (rev. 7/2/10)
Jan. 18. 2012 9:39AM
To:
Date:
Fax Number:

From:
Re:
Exhibit Six
, '.C'(" .,
s
AMERICAN CIVIL LIUERTIES UNION
of IIAWAI'I
FAX COVER SHEET
LvnneUyema
January 18 2012
529-3030
4[including this page)
Dan Gluck
Phone: (808) 522-5908; Fax: (808) 522-5909
UIP A Request
No.1780 P. 1
Dear Ms. Uyema: thank you very much for your phone call. Per our conversation, I understand
that our office recently sent you a Request to Access Government Records that was intended for
the Office, and that your office received the request intended for the Mayor. Attached is
the request that was intended for HPD. Because of the error, I will consider the window
for responding to the request to begin today, rather than from the date that the Mayor's Office
received 'the request to HPD. Please feel free to contact me via e-mail (dgluck@acluhawaii.org)
or phone (522-5908) if you have any questions.
This fax contains :mformation that may be confidential and privileged. Unless you are the
addressee (or authorized to receive for the addressee), you may not use, copy or disclose to
anyone the fax, the attaclunents or any information contained therein. If you have received this
fax in error, please advise the sender immediately.
Thank: you.
4
Jan. 18. 2012 9:40AM
Exhibit Six
",---_No. 1780_P. 2 __ ____,
}
REQUESTTOACCESSAGOVERNMENTRECORD
DATE: January 11. 2012
TO: Chief Louis M. Kealoha. Honolulu Police Department
FRO:M: Daniel M. Gluck
Name or Alias
ACLU of Hawaii. P.O. Box 3410. Honolulu. HI 96801
Phone: (808) 522-5908 e-mail: dgluck@ncluhawaii.org
Contact Information
Although you are not required to provide any personal information, you should provide enough informalion to allow the
agency to contact you about this request. The processing of this request moy be stopped If the agency is unable to contact
you. Therefore, please provide any informalion that will allow the agency to contact you (name or alios, telephone or fax
number, mailing address, e-mail address, etc.).
l WOULD LIKE THE FOLLOWING GOVERNMENT RECORDS:
Describe the govemment record as specifically as possible so thitt it can be located. Try to provide a record name, subject
matter, date, location, purpose, or names of persons to whom the record refers, or other information that could help the
agency Identify the record. A complete nnd accurate description of the government record you request will prevent delays in
locating the record. Attach ft second page if needed.
All current and/or proposed policies, procedures, guidelines, and/or rules regarding any Honolulu Police
Deportment (''HPD") Facebookpage (including, but not limited to, Honolulu Police Department (Official
Site) at http://www.facebook.com/honolulu.police?refl=ts. Honolulu Police Department (Group) at
http:/lwww.face!2ook.com/group.php?gid:=442S4302708, Honolulu Police Department (Organization) at
105577412808193, and Honolulu Police
Department (Company) at http://www.facebook.com/pages/Honolulu-Police-
Department/10544858:2823783), whether in draft or final fonn. This includes, but is not limited to, all
current or former policies, procedures, guidelines, and/or rules regarding the circumstances under which
individuals visiting any HPD Facebook page may be admitted to or prohibited from visiting, conuneming
on, or otherwise utilizing the site(s) This request also includes (but is not limited to) all current and/or
proposed policies, proced\lres, guidelines, and/or rules as to when and whethel' public comments on the
site may or must be allowed or removed.
From December l, 2011 to the present, all records relating to HPD's Facebook page(s) including, but not
limited to, any internal correspondence regarding removal of comments from HPD's Facebook page(s).
l WOULD LlKE: (please check one or more of the options below)
To inspect the government record.
0 A copy of the government record: (Please check one of the options below.) See the back of this page for
information about fees that you may be required to pay for agency services to process your record request. Note:
Copying and transmission charges may also apply to certain options.
0 Pick up at agency ( dnte and time):
DMail
0 Fox (toll free and only if available)
0 Other, if available (please specify):------------------
0 If the agency maintains the records in a fonn other than paper, please advise in which fonnat you
would prefer to have the record.
[ia Electronic Audio Other (pleMe specifY): However the records are maintained
Check this box If you ure anaohing a request for woiver of fees in the public interest
(see waiver infoilTilltlon on bock).
SEE BACK FOR IMPORTANT INFORMATION
OIP 1 (Jev. 9/12/01)
Jan. 18. 2012_ 9:40AM. _ ____,
Exhibit Six
1780_P. 3 __ ___,
FEES FOR PROCESSING RECORD REO'OESTS
You may be charged fees for the services that the agency must perform when processing your record
request, including fees for making photocopies and other lawful fees. The first $30 of fees charged for
searching for a record, re-viewing, and segregating will not be charged to you. Any amount over
$30 will be charged to you. Fees are as follows:
Search for a Record
Review and Segregation of a Record
W A.IVER OF FEES IN THE PuBLIC INTEREST
$2.50 for 15 minutes
$5.00 for 15 minutes
Up to $60 of fees for searching for, segregating and reviewing records may be waived when the waiver
would serve the public interest as described in section 2-71-32, Hawaii Administrative Rules. If you
wish to apply for a waiver of fees in the public 1nterest, you must attach to this request a statement of
facts, including your identtty as the requester, to show how the waiver of fees would serve the public
interest. The criteria for this waiver, found at section 2-71-32, Hawaii Administrative Rules, are:
(1) The requested record pertains to the operations or activities of an agency;
(2) The record is not readily available in the public domainj and
(3) The requester has the primary intention and the actual ability to widely disseminate
infonnation from the government record to the public at large.
l\GENCY RESPONSE TO YoUR REQUEST FOR ACCESS
The agency to which you addressed your request must respond Within a set time period. The agency
will normally respond to you within 10 business days from the date it receives your request; however, in
extenuating clrcnmstances the agency must respond within 20 business days from the date of your
request. If you have questions about the response time, you may contact the agency's UIPA contact
person. If you are not satisfied with the agency's response, you may call the Office of Infonnation
Practices at 808-586-1400.
;F.EOUESTER'S RESPONSIDILITIES
You have certain responsibilities under Hawaii Administrative Rules. You may obtain a copy
of these rules from the Lieutenant Governor's Office or from the Office of Information Practices. These
responstbllities include making arrangements to inspect and copy records, providing further clarification
or description of the requested record as instmcted by the agency's notice, and making a prepayment of
fees, if assessed.
OIP I (rev. 9/12/01)
Jan. 18. 2012_ 9:40AM._----r
Exhibit Six
o. 1780_P. 4 __ _,
ACLU of Hawaii Foundation Request to Access Goverrunent Records
Request for Waiver of Fees in the Public Interest
January 11, 2012
Pursuant to section 2-71-32 ofthe Hawaii Administrative Rules, the American Ctvil Liberties Union of
Hawaii Foundation ("ACLU") hereby requests a waiver of $60 of the fees that may be assessed under
section 2-71-31. The ACLU is a nonprofit, public" interest law f1tt11; our mission is to protect individual
freedoms guaranteed under the federal and state constitutions. The ACLU has been engaged in legal
action and public education in Hawaii since 1965 on issues affecting constttutional rights.
Public dissemination of the information contained in these documents will contribute significantly to
public knowledge and understanding of the Honolulu Police Department's policies and practices relating
to freedom of speech in HPD's social media forums. These documents are not readily available in the
public domain, The ACLU has frequently been at the forefront of monitoring and litigating free speech
concerns, has no connnercial interest in the docwnents requested, and intends to publicize this
information. As a publlc-mterest organization, the ACLU has both the primary intention and the actual
abtlity to disseminate this information in an appropriate manner: the ACLU has apptOximately 2,000
members state wide, and is able to disseminate this information to our members via out newsletter, our
Facebook page (which has over 2,200 "friends"), our website (which received over 3,000 hits in October
2011 alone), and our Twitter feed (which bas over 600 followers).
Requester respectfully asks that, if the total fees for this request (including copying charges) are
anticipated to exceed $150.00, Respondent notify Requester and obtain express written pennission to
proceed W1th the request.
OIP 1 (rev. 9/12/0l)
1
Exhibit Seven
Honolulu Police
On Sunday at 4:00am at a Punchbowl Street address, the victim Nas sleeping at
her apartment and was aNoken when she observed the 36 yr. old male suspect
masturbating next to her bed. She yelled at the suspect and he fled. On-duty HPD
police responded but suspect could not be located. Later, the suspect comes back
to the apartment, knocks on the door and apologizes and asks why the victim
called the police. The suspect is located by on-duty HPD police and the victim and
witness positively identify him. The suspect is arrested without incident.
like this.
Juliano Did they know each other or is this like some
law and order svu stuff
I t ~
Lol ... One of HaNaii's most dumbmess Professional
masturbating criminal.
iJ
KrisTina Orvlg that's NASTY, & why was he so dumb to come
back and to top if off asking why she called the cops .... Douche bag
award goes to him 1
r1arleen Vaimasanu'u What an idiot ...
i)
N<nk Carvalho I second that What an idiot..
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This is the offical Facebook page of
the Honolulu Police Department
3,221
like this
490
talking about this
See
of
Caitlin Ooofenshmirtz Homes
Has their been a report about a woman found dead on North Shore? My husband
was a part of a convey heading that way with the Army and he said a few people
noticed a lady laying on the side of the road, she had shopping bags and looked
dead. The command would not pull the convey over and they did not have a cell
phone to report the incidient, he said later on they saw an ambulance rushing
down that road. I have searched it and found nothing .. just wondering if it was a
bogus story or if someone was really found.
Caitlin Ooofenshmirtz Homes there"'
-
In my personal opinion, everyone who is caught talking on their cell phone while
they are driving should be made to demonstrate the importance of being safe on
the road. If I had my way, I'd have every officer confiscate the cell phone, put it
under the driver's tire, and have them run it over. V</ould save so many lives and
would teach people that a phone call is not worth their life or someone else's!
c--4
Exhibit Seven
Laureen
Capt. Andrew Lum "' Great 1V show interview on Ch26 ("Joy In Our
Town" show) about Safety on Roads and this Facebook site! Show
airing again Saturday-8/4@ 12:30 am, 8/6@ 8:30am,
Tuesday-8/7@ 12:30 am, Thursday-8/9@ 12:30am. Thank YOU for all
that you do!
Honolulu Police Thank you Laureen
tt 'Nas a pleasure, you're a great host! Thank you for getting our
message out to the public, much rnahalo!
IRS missing billions in ID theft
IRS missing billions in ID theft
Matt
Looking good Honolulu Police Department! Keep up the good v.,rork!!
Da likes this.
Honolulu Police
Aloha.
Thank you Matt!
3
Exhibit Seven
Honolulu
Our Brother, as you now patrol the streets of Heaven, ma)' you
continue your vigilant watch over us all as we carry on in our Brother's
Honor. We thank you for vour service and for your sacrWice. We thank
you for your lk Job Vleil Done Sir.
Rest Jn Peace Sob Bike Officer Chad f1orimoto ... vVe have the watch
from here. SALUTE
1
We must vow to never let his children forget how their daddy Lived As
Only A Hero Could. This husband, father, son and Brother of Blue wiii be
missed by so very many ... forgotten by so few. Please take a moment
to read of How this Hero LlVED by clicking on photo
Our heartfelt thoughts and pravers go out to the entire extended
r1orimoto family, the f1en and Women of the Honolulu PO and to all
whom have had the pleasure and the privrlege of knowing and working
along side this True Blue Hero. This tight-knit agency has been through
so much heartache this past year and we our hearts break for our
Brothers and Sisters. But this Hawaiian Blue Ohana is also one of the
most resilient group of men and women you wrll know know and they
will find a \'Jay to pull it all together, yet again, and they will valiantly
continue to do the best in their service to their community honoring
their fallen all the while.
II
4

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Case 1:12-cv-00469-JMS-RLP Document 7-1 Filed 08/21/12 Page 1 of 17 PageID #:

khehded' \inJ Restated Articles of Incorporation,

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