A. EDWARD FYFFE, JR. 1380 828 Fort Street Mall, Suite 320 Honolulu, Hawai'i 96813

"

Telephone No, (808) 218-4847; 735-2138 2GJ£HAY 25 Ar1 2: 34

Attorney for PLAINTIFFS

IN THE CIRCUIT COURT OF THE FIRST CIRCUIT

STATE OF HAWAI'I

MR. SANDMAN INC., a Hawai'i ) CIVIL NO. 05-1-2156-12 BIA corporation; ROBERT l. FREEMAN, ) (Other Non-Vehicle Tort) Individually; RANDALL W. WONG, ) Individually, dba TLC Motorcycle Repair, )) FIRST AMENDED COMPLAINT; THE SO LARA Y CORPORATION, a SUMMONS Hawai'i corporation dba Inter-Island Solar ~ Supply, LAWRENCE M. JUDD, III, ) Individually; PACIFIC JOBBERS } WAREHOUSE, INC., a Hawai'i ) corporation; MUTUAL PLUMBING ) SUPPLY, INC., a Hawai'i corporation; ) CLYDE T. KOJIMA, Individually; ALLISON ) C. KOJIMA, Individually; HAWAII ) COOLING SYSTEMS, L.L.C., a Hawari } limited liability company dba Aloha ) Radiator, RODNEY W.J. HO, Individually; ~ BTK, INC., a Hawai'i corporation dba Benton's Ahua Street Chevron; BIG ROCK ~ MANUFACTURING, INC., a Hawai'i ) corporation; BONNIE l. COOPER, ) Individually; BRIAN S. JOY, Individually; ) MEDALLION, a division of STURLA, INC., ) a Nevada corporation; MICHAEL G. ) TAKAMOTO, Individually; BENNY'S AUTO) BODY, INC., a Hawai'i corporation; } BILLION C. JOHNSTON, Individually, dba }} Discount Applian~~ Warehouse; JODI J. ) JOHNSTON, IndiVidually; BLB, 1.1.C., a ) Hawai'i limited liability company dba )

CLERK

Sunset Tile & Stone; ROBERT W. STARK, } Individually; LYNDA S.K. STARK, ) I do hereby certify that this is a full, true, and Individually; H.Q. , INC., a Hawai'i ) correctcopyoft;,~originalonfUeinthisolfice-.

corporation, dba Aloha Products; HWA ) YOUNG CHANG, Individually; KYU HWAN )

)

Page 1 of 12

· CHUNG, Individually; HAWAII NUT & ) BOLT, INC., a Hawai'i corporation; ) WILLIAM R. HAYES III, Individually; ) WILLIAM R. HAYES, JR., Individually; ) CLASSIC MOTORCYCLES OF HAWAII, ~ INC., a Hawai'i corporation; LAST ) CHANCE MOTORCYCLE REPAIR, INC., ) a Hawai'i corporation; EDMOND G. ) SCHUMAN, Individually; DIANA F. ) SCHUMAN, Individually; ) HANS K. SCHUMAN, Individually; ) PHILLIP K. SCHUMAN, Individually; ) EDMOND H. SCHUMAN, Individually; ) MEGA CONSTRUCTION, INC., a Hawai'i ) corporation; MARVIN R. KOGA, )) Individually; A. MARGO KOGA, Individually; SAFWAY SERVICES, INC., A~ Delaware corporation; TOKUNAGA ) MASONRY, INC., a Hawai'i corporation; ) EDWARD H. TOKUNAGA, Individually; ) LORNA T. TOKUNAGA, Individually; ) FORDE F. HIGUCHI, dba Guchi ) Contracting; JNS AUTO, INC., a Hawai'i ) corporation; ANWARUL HAQ, Individually;) and ABDUL HAQ, Individually; CHING ) NINA YI aka NINA YI, Individually; NICK ~ P. PATCHRAPONG, Individually; ) KATHLEEN PATCHRAPONG, Individually; MIGUEL TAGABI, ~ Individually; LAVERNE LEIMOMI ) KANAHELE, Individually; JAMES KEALII ) KEONE HOSE KANAHELE aka KIMO ) HOSE KANAHALE, Individually; NADINE) KIYONAGA, Individually; CRAIG ) KIYONAGA, Individually; and RELIANT ) ENTERPRISE, INC., a Hawai'i ) corporation; ~

PLAINTIFFS,

vs.

CITY & COUNTY OF HONOLULU, a Hawai'i municipal corporation; JOHN DOES 1-20; JANE DOES 1-20; DOE CORPORATIONS 1-20; DOE

) ) ) ) ) ) ) ) ) )

Page 2 of 12

PARTNERSHIPS 1-20; DOE LIMITED LIABILITY COMPANIES 1-20; DOE ENTITIES 1-20; and DOE GOVERNMENTAL ENTITIES 1-20,

Defendants.

) ) ) ) ) )

--------------------------)

ARST AMENDED COMPLMNT

COME NOW PLAINTIFFS above-named ("PLAINTIFFS"), by and through their

attorney, A. EDWARD FYFFE, JR., and for complaint against Defendants above-named

allege and aver as follows:

PARTIES AND JURISDICTION

1. At all times relevant to this FIRST AMENDED COMPLAINT, the following

PLAINTIFFS were and are Hawai'i corporations duly organized under the laws of the

State of Hawai'i and authorized to do business within the State of Hawai'i, with their

principal places of business located within the First Circuit, State of Hawai'i, and in

particular within Mapunapuna Industrial Subdivision (hereinafter "Mapunapuna"): MR.

SANDMAN INC.; THE SOLARAY CORPORATION dba Inter-Island Solar Supply;

PACIFIC JOBBERS WAREHOUSE, INC.; MUTUAL PLUMBING SUPPLY, INC.; BTK,

INC. dba Benton's Ahua Street Chevron; BIG ROCK MANUFACTURING, INC.; BENNY'S

AUTO BODY, INC.; H.Q., INC.dba Aloha Products; HAWAII NUT & BOLT, INC.;

CLASSIC MOTORCYCLES OF HAWAII, INC.; LAST CHANCE MOTORCYCLE REPAIR,

INC.; MEGA CONSTRUCTION, INC.; JNS AUTO, INC.; TOKUNAGA MASONRY, INC.;

and RELIANT ENTERPRISE, INC.

2. At all times relevant to this FIRST AMENDED COMPLAINT, PLAINTIFF

MEDALLION was and is a division of STURLA, INC., a Nevada Corporation registered to

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do business in the State of Hawai'i, with its principal place of business located within the

First Circuit, State of Hawai'i, and in particular within Mapunapuna. At all times relevant to

this FIRST AMENDED COMPLAINT, PLAINTIFF SAFWAY SERVICES, INC. was and is a

Delaware corporation registered to do business in the State of Hawai'i, with its principal

place of business within the First Circuit, State of Hawai'i and, at the time of the incident

complained of, within Mapunapuna.

3. At all times relevant to this FIRST AMENDED COMPLAINT, the following

PLAINTIFFS were and are Hawai'i limited liability companies duly organized under the

laws of the State of Hawai'i and authorized to do business within the State of Hawai'i, with

their principal places of business located within the First Circuit, State of Hawai'i, and in

particular within Mapunapuna: HAWAII COOLING SYSTEMS, L.L.C. dba Aloha Radiator,

and BLB, L.L.C. dba Sunset Tile & Stone.

4. At all times relevant to this FIRST AMENDED COMPLAINT, the following

PLAINTIFFS were and are residents of the First Circuit, State of Hawai'i, and did and do

business as sole proprietors located within the First Circuit, State of Hawai'i, and in

particular within Mapunapuna, and are proceeding in their individual capacities:

RANDALL W. WONG, dba TLC Motorcycle Repair, BILLION C. JOHNSTON, dba

Discount Appliance Warehouse; and FORDE F. HIGUCHI, dba Guchi Contracting.

5. At all times relevant to this FIRST AMENDED COMPLAINT, the following

PLAINTIFFS were and are residents of the First Circuit, State of Hawai'i, and are

proceeding in their individual capacities: ROBERT L. FREEMAN; TETSUJIIDETA;

MICHAEL G. TAKAMOTO; LAWRENCE M. JUDD, III; CLYDE T. KOJIMA; ALLISON C.

KOJIMA; RODNEYW.J. HO; BONNIE L. COOPER; BRIAN S. JOY; HWA YOUNG

Page 4 of 12

CHUNG; KYU HWAN CHUNG; ROBERT W. STARK; LYNDA S.K. STARK; WILLIAM R.

HAYES, III.; JODI J. JOHNSTON; EDMOND G. SCHUMAN; DIANA F. SCHUMAN; HANS

K.SCHUMAN; PHILLIP K. SCHUMAN; EDMOND H. SCHUMAN; MARVIN R. KOGA; A.

MARGO KOGA; EDWARD H. TOKUNAGA; LORNA T. TOKUNAGA; ANWARUL HAQ;

ABDUL HAQ; CHING NINA YI also known as NINA YI; NICK P. PATCHRAPONG;

KATHLEEN PATCHRAPONG; MIGUEL TAGABI; NADINE KIYONAGA; CRAIG

KIYONAGA; LAVERNE LEIMOMI KANAHELE; AND JAMES KEALII KEONE HOSE

KANAHELE also known as KIMO HOSE KANAHELE. PLAINTIFF WILLIAM R. HAYES,

JR., currently a resident of Eureka, Montana, is also proceeding in his individual capacity.

6. At all times relevant to this FIRST AMENDED COMPLAINT, Defendant City

& County of Honolulu ("Defendant City") was and is a municipal corporation duly

organized under the laws of the State of Hawai'i and a political subdivision thereof and

subordinate thereto in matters relevant to this law suit. Defendant City operated and

operates within and throughout the First Circuit, State of Hawai'i. Defendant CITY has the

capacity to be sued pursuant to Hawai'i Revised Statutes Chapter 46.

7. All Defendants JOHN DOES 1-20, JANE DOES 1-20, DOE

CORPORATIONS 1-20, DOE LIMITED LIABILITY COMPANIES 1-20, DOE

PARTNERSHIPS 1-20, DOE ENTITIES 1-22, and DOE GOVERNMENTAL ENTITIES

1-20 are sued herein under fictitious names for the reason that their true names and

identities are presently unknown to PLAINTIFFS, except that they are connected in

some manner with the named Defendant(s) and/or were the principals, agents,

representatives, directors, officers, servants, employees, employers, subsidiaries, co­

venturers, partners, associates, vendors, suppliers, manufacturers, contractors,

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subcontractors, owners, lessees, sub lessees, lessors, sureties, insurers, assignees,

assignors, successors, licensees, designees, designers, and/or engineers of the named

Defendant(s), and/or in some manner presently unknown to PLAINTIFFS engaged in

activities alleged herein and/or were in some manner liable and/or responsible for the

injuries or damages to PLAINTIFFS, and/or conducted and/or failed to conduct some

activity in a negligent of dangerous manner, which said conduct and/or its failure was a

proximate cause of injuries and/or damages to PLAINTIFFS, and/or were in some

manner related to the named Defendant(s). PLAINTIFFS reserve their right to and pray

for leave to insert herein for any of the DOE Defendants the true names, identities,

capacities, activities, liabilities, and/or responsibilities when the same are ascertained.

8. All incidents complained of occurred within the First Circuit, State of Hawai'i.

9. Damages suffered by PLAINTIFFS and each of them exceed the

jurisdictional threshold for the Circuit Courts of the State of Hawai'i.

COUNTI-NEGUGENCE

10. Moanalua Stream is a channel, stream, and/or drainage way running mauka

to makai and through the business and commercial area of Mapunapuna.

11 . At the time of and for a period of time prior to the incident complained of

herein, by statute, ordinance, resolution, case law, practice, tradition, understanding,

contract, agreement, default, fiat, and/or otherwise, Defendant City had a duty to maintain

relevant segments of Moanalua Stream in a condition suitable to carry off storm waters, or

otherwise prevent Moanalua Stream from overflowing its banks.

12. Defendant City's duty was imposed inter alia by state legislative mandate

which required Defendant City "to provide for the maintenance of channels, streambeds,

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stream banks, and drainage ways, whether natural or artificial, including their exits to the

ocean, in suitable condition to carry off storm waters."

13. Over a period of time prior to and up to the time of the incident complained

of here, Defendant City failed to maintain Moanalua Stream in a condition suitable to carry

off storm waters or otherwise prevent it from overflowing its banks.

14. Among other failures, Defendant City permitted Moanalua Stream to fill with

silt, debris, trees, and other vegetation.

15. Although reasonable means were available to dredge, clear, or otherwise

maintain Moanalua Stream in a condition suitable to carry off storm waters or otherwise

prevent it from overflowing its banks, the City failed to do so.

16. This failure under the circumstances was unreasonable.

17. By failing to maintain Moanalua Stream in a condition suitable to carry off

storm waters, and/or otherwise prevent it from overflowing its banks, Defendant City

breached its duty to maintain Moanalua Stream "in suitable condition to carry off storm

waters", or otherwise prevent it from overflowing its banks.

18. On December 7,2003, storm waters coursing through Moanalua Stream

were not carried off but overflowed the banks of Moanalua Stream, extensively flooding

and inundating relevant sections of Mapunapuna, most pertinently sections where the

PLAINTIFFS were engaged in their ordinary, lawful business and commercial activities.

19. As a result of the flooding and inundation, PLAINTIFFS and each of them

suffered damages of every recoverable type and description, including, by way of example

and not limitation, losses from the compromise and/or destruction of materials, supplies,

parts, accessories, hardware, equipment, furnishings, fixtures, inventory, product, property

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held as bailees, business records, financial records, library, and/or realty and/or personalty

of every type and description.

20. Also as a result of the flooding and inundation, PLAINTIFFS and each of

them suffered damages as well from additional labor charges, salvage and clean up costs,

costs of repair and/or restoration and/or renovation, costs of relocation, lost accounts

receivable, diminished receipts, reduced cash flow, lost profits, lost production time, "down

time", extended hours, overtime, the cost of diverted capital, interest expense, diminution

of good will, costs of additional advertising and marketing, offsets and/or incentives and/or

discounts, other economic losses, the defense, compromise, and payment of adverse

claims, prosecution of claims, medical and healthcare expenses, attorney's fees, legal

costs and charges, and/or other recoverable and/or compensable costs, expenses,

losses, and/or injury of every type and description.

21. In the case of those PLAINTIFFS who are proceeding individually, the

damages suffered included injuries to their persons for which those PLAINTIFFS are also

entitled to special damages and general damages for pain and suffering.

22. The damages PLAINTIFFS and each of them suffered were foreseeable.

23. Defendant City's breach of its duty to maintain relevant sections of Moanalua

Stream in a condition suitable to carry off storm waters or otherwise prevent it from

overflowing its banks was the proximate cause of the damages suffered by the

PLAINTIFFS and each of them.

25. For each PLAINTIFF, the damages suffered are demonstrable and

verifiable, the exact amounts to be proved at trial.

COUNT II - NUISANCE

Page 8 of 12

· 26. PLAINTIFFS repeat, re-allege, and incorporate herein by reference all

allegations contained in all preceding paragraphs of this FIRST AMENDED COMPLAINT.

27. In addition to the legislative mandate to maintain Moanalua Stream in a

condition suitable to carry off storm waters, Defendant City was also charged with

preventing or abating any nuisance that debris in the stream was likely to become.

28. Defendant City's duty to prevent or abate any nuisance was imposed inter

alia by state legislative mandate which required Defendant City to provide "for the removal

from the channels, streambeds, streambanks, and drainage ways ... any debris which is

likely to ... becomea public nuisance."

29. The flood of December 7,2003 was not the first such flood in Mapunapuna,

but a reoccurring event.

30. Debris had accumulated within Moanalua Stream before.

31. Defendant knew or should have known about the recurrences.

32. Defendant City was on notice.

33. PLAINTIFFS or some of them complained to the Defendant City about the

unsuitable condition of Moanalua Stream, some of them repeatedly.

34. The accumulation of debris and the recurrence of flooding constituted a

nuisance created and maintained by Defendant City, in contravention of state legislative

mandate and other applicable law.

35. Accumulating debris and recurring floods caused and will continue to cause

PLAINTIFFS damage to an extent for which there is no adequate remedy at law.

36. Compliance with a statutory mandate may not be asserted as an undue

hardship. Any professed hardship Defendant City might allege from compliance would in

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any case be more than outweighed by the damages PLAINTIFFS suffered and will

continue to suffer.

3? Therefore, PLAINTIFFS are entitled to an Order of Abatement wherein the

debris within Moanalua Stream is declared a nuisance, the flooding is declared a

nuisance, and Defendant City is permanently enjoined and restrained from creating or

maintaining the nuisance complained of.

COUNT III - TRESPASS

38. PLAiNTIFFS repeat, re-allege, and incorporate herein by reference all

allegations contained in all preceding paragraphs of this FIRST AMENDED COMPLAINT.

39. By its failure to maintain Moanalua Stream in a condition suitable for the

passage of storm waters, Defendant City caused storm waters and debris and other things

to trespass upon the premises and property of the PLAINTIFFS and, in the case of those

PLAINTIFFS who are proceeding individually, the trespass was also upon their persons.

40. These trespasses were without authority, condition, privilege, warrant, or

invitation, express or implied.

41. As a proximate cause of these trespasses, PLAINTIFFS suffered damages

of every type and description, all as more fully presented in COUNT I, above.

42. In the case of those PLAINTIFFS who are proceeding individually or some of

them, the damages suffered included injuries to their persons for which those PLAINTIFFS

are also entitled both to special damages and to general damages for pain and suffering.

COUNT IV - NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS

43. PLAINTIFFS who are proceeding individually repeat, re-allege, and

incorporate herein by reference all allegations contained in all preceding paragraphs of this

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FIRST AMENDED COMPLAINT.

44. Defendant City had a duty of due care to each of the PLAINTIFFS

proceeding individually.

45. Defendant City breached its duty of due care, and caused the PLAINTIFFS

proceeding individually or some of them to suffer emotional distress of the type with which

a reasonable person normally constituted would be unable to cope.

46. These damages were foreseeable.

47. The breach by Defendant City was the proximate cause of these damages.

48. These damages are demonstrable and verifiable, in amounts to be proved at

trial.

PRAYER FOR RELIEF

WHEREFORE, PLAINTIFFS and each of them pray for Judgment against

Defendant City on all COUNTS, or anyone COUNT or combination of COUNTS, as

follows:

A. For all PLAINTIFFS, special, general, consequential, and/or actual damages

in amounts to be proved at trial;

B. For the PLAINTIFFS proceeding individually, for additional amounts for

special and general damages for personal injury and/or emotional distress;

C. For prejudgment interest pursuant to Hawar i Revised Statutes §636-16;

D. For an Order of Abatement declaring the accumulating debris and flooding

storm waters a nuisance created and maintained by Defendant City, and for a permanent

injunction against Defendant City's continued creation and maintenance of this nuisance;

E. For costs and reasonable attorney's fees; and

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F. For such other and further relief as the Court deems just and equitable.

DATED: May 19, 2006

. A. EDWARD FYFFE, JR. Attorney for PLAI NTI FFS

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A. EDWARD FYFFE, JR. 1380 Attorney at Law 828 Fort Street Mall, Suite 320 Honolulu, Hawaii 96813 Telephone No. (808) 218-4847; 735-2138

Attorney for PLAI NTI FFS

IN THE CIRCUIT COURT OF THE FIRST CIRCUIT

STATE OF HAWArl

MR. SANDMAN INC., a Hawai'i ) corporation; ROBERT L. FREEMAN, ) Individually; RANDALL W. WONG, ) Individually, dba TLC Motorcycle Repair, )) THE SOLARA Y CORPORATION, a Hawai'i corporation dba Inter-Island Solar ~ Supply, LAWRENCE M. JUDD, III, ) Individually; PACIFIC JOBBERS ) WAREHOUSE, INC., a Hawai'i ) corporation; MUTUAL PLUMBING ) SUPPLY, INC., a Hawai'i corporation; ) CLYDE T. KOJIMA, Individually; ALLISON ) C. KOJIMA, Individually; HAWAII ) COOLING SYSTEMS, L.L.C., a Hawai'i ) limited liability com'pany dba Aloha' ) Radiator, RODNEY W.J. HO, Individually; ~ BTK, INC., a Hawai'i corporation dba Benton's Ahua Street Chevron; BIG ROCK ~ MANUFACTURING, INC., a Hawai'i ) corporation; BONNIE L. COOPER, ) Individually; BRIAN S. JOY, Individually; ) MEDALLION, a division of STURLA, INC., ) a Nevada corporation; MICHAEL G. ) TAKAMOTO, Individually; BENNY1S AUTO) BODY, INC., a Hawai'i corporation; ) BILLION C. JOHNSTON, Individually, dba )) Discount Applian?~ Warehouse; JODI J. ) JOHNSTON, IndiVidually; BLB, L.L.C., a ) Hawai'i limited liability company dba ) Sunset Tile & Stone; ROBERTW. STARK, ) Individually; LYNDA S.K. STARK, ) Individually; H.Q. , INC., a Hawai'i ) corporation, dba Aloha Products; HWA ) YOUNG CHANG, Individually; KYU HWAN ) CHUNG, Individually; HAWAII NUT & )

1

CIVIL NO. 05-1-2156-12 (BIA) (Other Non-Vehicle Tort)

SUMMONS

BOLT, INC., a Hawai'i corporation; ) WILLIAM R. HAYES III, Individually; ) WILLIAM R. HAYES, JR., Individually; ) CLASSIC MOTORCYCLES OF HAWAII, ) INC., a Hawai'i corporation; LAST ~ CHANCE MOTORCYCLE REPAIR, INC., ) a Hawai'i corporation; EDMOND G. ) SCHUMAN, Individually; DIANA F. ) SCHUMAN, Individually; ) HANS K. SCHUMAN, Individually; ) PHILLIP K. SCHUMAN, Individually; ) EDMOND H. SCHUMAN, Individually; ) MEGA CONSTRUCTION, INC., a Hawai'i ) corporation; MARVIN R. KOGA, ) Individually; A. MARGO KOGA, ) Individually; SAFWAY SERVICES, INC., A~ Delaware corporation; TOKUNAGA MASONRY, INC., a Hawai'i corporation; ~ EDWARD H. TOKUNAGA, Individually; ) LORNA T. TOKUNAGA, Individually; ) FORDE F. HIGUCHI, dba Guchi ) Contracting; JNS AUTO, INC., a Hawai'i ) corporation; ANWARUL HAQ, Individually;) and ABDUL HAQ, Individually; CHING ) NINA YI aka NINA YI, Individually; NICK ) P. PATCHRAPONG, Individually; » KATHLEEN PATCHRAPONG, Individually; MIGUEL TAGABI, ) Individually; LAVERNE LEIMOMI ~ KANAHELE, Individually; JAMES KEALII ) KEONE HOSE KANAHELE aka KIMO ) HOSE KANAHALE, Individually; NADINE ) KIYONAGA, Individually; CRAIG ) KIYONAGA, Individually; and RELIANT ) ENTERPRISE, INC., a Hawai'i ) corporation; )

Plaintiffs,

vs.

CITY & COUNTY OF HONOLULU, a Hawai'i municipal corporation; JOHN DOES 1-20; JANE DOES 1-20; DOE CORPORATIONS 1-20; DOE PARTNERSHIPS 1-20; DOE LIMITED LIABILITY COMPANIES 1-20; DOE

) ) ) ) ) ) ) ) ) ) ) ) )

2

~NTITIES 1-20; and DOE GOVERNMENTAL ENTITIES 1-20;

Defendants.

) ) ) )

---------------------------)

SUMMONS

TO THE DEFENDANT(S):

You are hereby summoned and required to serve upon plaintiff's attorney, whose address is stated above, and answer to the FIRST AMENDED COMPLAINT which is attached. This action must be taken within twenty days after service of this summons upon you, exclusive of the day of service.

If you fail to make your answer within the twenty day time limit, judgement by default will be taken against you for the relief demanded in the FIRST AMENDED COMPLAINT.

This summons shall not be personally delivered between 10:00 p.m. and 6:00 a.m. on premises not open to the general public, unless a judge of the above­entitled court permits, in writing on this summons, personal delivery during those hours.

A failure to obey this summons may result in an entry of default and default judgement against the disobeying person or party.

In accordance with the American with Disabilities Act, and other applicable state and federal laws, if you require a reasonable accommodation for a disability, please contact the ADA Coordinator at the First Circuit Court Administration Office at PHONE NO. 539-4333, FAX 539-4322, or TTY 539-4853, at least ten (10) working days prior to your hearing or appointment date.

DATE ISSUED: CLERK MAY 25, 2006

I do hereby certify that this is a full, true, and correct copy of the original on file in this office.

TWONG

CIRCUIT COURT CLERK

3 I