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.
7511301DEFENDANTS 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.
75113013. 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