Angela Kaaihue -vs- Newtown Estates Community Association in Counter-claim.

1. MS. ANGELA KAAIHUE
PROSE
98-673 KILINOE ST
AIEA, HI. 96701
(808) 542-9393
IN THE CIRCUIT COURT OF THE FIRST CIRCUIT
STATE OF HAWAII
NEWTOWN ESTATES COMMUNITY CIVIL . NO. 13-1-2161-08 JHC
ASSOCIATION, BY IT’S BOARD OF DIRECTORS (OTHER CIVIL ACTION)
PLAINTIFF,
Vs.
DEFENDANT ANGELA KAAIHUE,
AND YOUNG FRYER ANSWER
COMPLAINT FILED AUG. 7, 2013;
PLAINTIFF COUNTERCLAIM;
DEMAND FOR JURY TRIL;
CERTIFICATE OF SERVICE
ANGELA SUE KAAIHUE; YOUNG NAM FRYER;
JOHN DOES 1-50; JANE DOES 1-50; DOE
PARTNERSHIPS 1-50; DOE CORPORATIONS 1-50;
DOE GOVERNMENTAL AGENCIES 1-50; AND
DOES ENTITIES 1-50,
DEFENDANTS
______________________________________________
DEFENDANTS ANGELA KAAIHUE AND YOUNG NAM FRYER’S
ANSWER TO FRIVILOUS COMPLAINT FILED AUG. 7 2013
COME NOW Defendants Angela Kaaihue (“Kaaihue”), Young Nam Fryer(“Fryer”)
(“Collectively “Defendants”), John Doe 1-50; Jane Doe 1-50; Doe Partnerships 1-50, DOE Corporations
1-50; DOE Governental Agencies 1-50; and DOES Entities 1-50, by and through their undersigned
attorney, and for our answer to the Complaint filed on Aug. 7, 2013 (“Complaint”), allege and aver as
follows.

3. FIRST DEFENSE
1. The Complaint fails to state a claim against Defendants upon which relief can be granted.
SECOND DEFENSE
2. Defendants AGREE to the statements contained in paragraphs 1 of the PARTIES.
3. Defendants DENY Paragraph 2 & 3 of the PARTIES. Defendants ANGELA KAAIHUE AND YOUNG
FRYER are without sufficient information to determine the truth or falsity of the allegations
contained in Paragraph 3, and therefore deny the same.
4. Defendants AGREE to paragraph 4 of the PARTIES
5. Defendants DENY Paragraph 5 of the PARTIES. Defendants ANGELA KAAIHUE AND YOUNG FRYER
are without sufficient information to determine the truth or falsity of the allegations contained
in Paragraph 5, and therefore deny the same.
6. Defendants AGREE to the JURISDITION AND VENUE as contained in Paragraph 6.
7. Defendants DENY the allegations as set forth in paragraphs 7-10,
8. Defendants AGREE in part to paragraphs 11-14 but DENY in part as to lack of sufficient
information to determine the truth or falsity of the allegations contained in Paragraph 11-14.
9. DEFENDANTS DENY 15-21, Defendants ANGELA KAAIHUE AND YOUNG FRYER are without
sufficient information to determine the truth or falsity of the allegations contained in Paragraph
15-21, and therefore deny the same.
10. Defendants DENY paragraph 22. Defendants ANGELA KAAIHUE AND YOUNG FRYER are without
sufficient information to determine the truth or falsity of the allegations contained in Paragraph
22, and therefore deny the same.

4. 11. Defendants DENY Paragraph 24-27. Defendants ANGELA KAAIHUE AND YOUNG FRYER are
without sufficient information to determine the truth or falsity of the allegations contained in
Paragraph 24-27, and therefore deny the same.
12. Defendants are without information or knowledge sufficient to form a belief as to the truth or
falsity of the allegations set forth in paragraph 28-32 of the Complaint, and on that basis, DENY
the same.
13. Defendants are without information or knowledge sufficient to form a belief as to the truth or
falsity of the allegations set forth in paragraph 33-37 of the Complaint, and on that basis, DENY
the same.
14. Defendants DENY paragraph 20 that Defendants “Kaaihue” , and “Fryer” received numerous
letters, date June 28, 2013, attached as Exhibit “1” to the Complaint, with respect to the
allegations of the Complaint, the terms of which and enclosures speak for themselves, but are
without information or knowledge sufficient to form a belief as to the truth or falsity of the
remaining allegations set forth in the paragraph and, on that basis, DENY the same.
15. As to any other future allegations set forth in the Complaint, Defendants repeat and reallege
their answers as set forth above.
16. Defendant DENY and all allegations not expressly admitted herein.
THIRD DEFENSE
17. Defendants invoke the economic loss rule
FOURTH DEFENSE
18. Plaintiff is barred from maintaining this action against Defendants because Plaintiff failed to
comply with all of the terms and conditions of Master Declaration of Covenants, Conditions, and
Restrictions.

5. FIFTH DEFENSE
19. Plaintiff is barred from maintaining this action against Defendants by reason of it’s own
contributory negligence or other wrongful conduct which causes the damages alleged in this
Complaint.
SIXTH DEFENSE
20. Plaintiff’s recover in this action, if any, should be reduced in accordance with Hawaii Revised
Statutes 663-31.
SEVENTH DEFEENSE
21. Plaintiff is barred from maintaining this action against Defendants by reason of Plaintiff’s
voluntary assumption of a known risk.
EIGTH DEFENSE
22. Plaintiff’s recovery in this action, if any, should be reduced in accordance with the doctrine of
avoidable consequences.
NINTH DEFENSE
23. Defendants will rely on the defense of estoppel.
TENTH DEFENSE
24. Defendants will rely on upon the of defense of unclean hands.
ELEVENTH DEFENSE
25. Defendants will rely on upon the defense of fraud

6. TWELFTH DEFENSE
26. Defendants will rely on upon the defense of waiver.
THIRTEENTH DEFENSE
27. Defendants will rely on the defense of set off.
FOURTEENTH DEFENSE
28. Defendant’s reserves the right to assert any other defenses, including but not limited to those
affirmative defenses set forth in Hawaii Rules of Civil Procedure Rule 8, for lack of discovery.
Defendants give notice that because Plaintiff’s Complaint is couched in conclusory terms,
Defendants cannot fully anticipate all affirmative defenses that may be application to this
action. Accordingly, the right to assert additional defenses, if and to the extent that such
defenses are applicable, is hereby reserved. Defendant’s further reserve all rights to bring and
assert further claims and counter-claims, as discovery and the evidence may merit, and also
reserve the right to name additional parties to this action.
WHEREFORE, Defendants pray that judgment be entered in their favor and that:
A. The Complaint be dismissed with prejudice;
B. Enter judgment in Defendants favor and against Plaintiff as to all claims set forth in the
Complaint;
C. Award Defendants the fees, and costs it reasonably incurred herein; their attorney fees,
costs, and expenses;
D. Provide Defendants with such other and further relief as is just and equitable under the
circumstances.

7. DATED: Honolulu, Hawaii __________________________________________
_____________________________________
MS. ANGELA S. KAAIHUE
Pro-Se for Defendants
ANGELA KAAIHUE, and
YOUNG NAM FRYER

8. MS. ANGELA KAAIHUE
PROSE
98-673 KILINOE ST
AIEA, HI. 96701
(808) 542-9393
IN THE CIRCUIT COURT OF THE FIRST CIRCUIT
STATE OF HAWAII
ANGELA KAAIHUE, YOUNG FRYER CIVIL. NO. 13-1-2161-08 JHC
(OTHER CIVIL ACTION)
PLAINTIFFS
VS- PLAINTIFF ANGELA KAAIHUE
AND YOUNG FRYER
CROSS-CLAIM
NEWTOWN ESTATES COMMUNITY
ASSOCIATION, BY IT’S BOARD OF DIRECTORS
JOHN DOES 1-50; JANE DOES 1-50; DOE
PARTNERSHIPS 1-50; DOE CORPORATIONS 1-50;
DOE GOVERNMENTAL AGENCIES 1-50; AND
DOES ENTITIES 1-50,
DEFENDANTS
______________________________________________
COUNTERCLAIM
COMES NOW PLAINTIFFS ANGELA KAAIHUE AND YOUNG FRYER (Defendants) individually, and
married, respectively, by its own self, for its counterclaim against DEFENDANTS NEWTOWN ESTATES
COMMUNITY ASSOCIATION, BY IT’S BOARD OF DIRECTORS, Plaintiffs alleges and avers as follows:

10. INTRODUCTION
This suit concerns a vacant land parcel situated in Waimalu, of real property described
as LOT 881-B-5, located at 98-783 Kilinoe St., Aiea. HI. 96701. TMK. 9-8-073-002. previously
owned by Developer and Declarant of NEWTOWN ESTATES COMMUNITY ASSOCIATION, Herbert
Horita whom past away in December of 2011, and previous owner Wallace Lean whom since has
deceased. PLAINTIFFS ANGELA KAAIHUE AND YOUNG FRYER inherited the property in 2009.
On or about the year of 2011, the DEFENDANTS NEWTOWN ESTATES COMMUNITY
ASSOCIATION BY IT’S BOARD OF DIRECTORS began to imply fines upon her of a quarterly
association fees and dues, violations, fines, and attorney fees, yet the property continued to
remain as a vacant and undeveloped land parcel.
In 1972, when Developer and Declarant Herbert Horita established the Newtown
Estates Community Association, he never once through the 35+ years or ownership following
was he deemed or classified as “owner” or was this land parcel declared a “lot” as (defined in
MDCCR Article 1), and as described in the NEWTOWN MASTER DECLARATION OF COVENANTS,
CONDITIONS, AND RESTRICTIONS (MDCCR), Article V, Section 5.02- Membership) of this
particular 82-Acre vacant land parcel. Neither did previous Land-owner and Developer Wallace
Lean II.
This parcel was either NOT subjected to the developed NEWTOWN MDCCR’s, rules, and
covenants as stated in MDCCR, Article VII, Sec. 7.10, or was excluded. Now, that PLAINTIFFS
ANGELA KAAIHUE AND YOUNG FRYER have acquired the property through inheritance in 2009,
DEFENDANTS NEWTOWN ESTATES COMMUNITY ASSOCIATION BY AND THROUGHS IT’S BOARD
OF DIRECTORS has made rebuttable attempts to imply and enforce such rules. The
DEFENDANTS attempts to accrue attorney fees, unpaid association dues and , frivolous
numerous violations to the PLAINTIFFS, upon this undeveloped land parcel and to the current

11. land-owner PLAINTIFFS ANGELA KAAIHUE AND YOUNG FRYER, by attempting to misconstrue,
and imply NEWTOWN’S MDCCRS either by discrimination, paraphrasing, and intentional
misconstruing the Newtown MDCCR’s declared and , established by Developer and Newtown’s
MDCCR’s Declarant Herbert Horita.
PARTIES
Come now, PLAINTIFFS ANGELA KAAIHUE AND YOUNG FRYER, both reside in Hawaii.
She brings this suit on her own behalf.
DEFENDANTS NEWTOWN ASSOCIATION COMMUNITY ASSOCIATION by and through
it’s BOARD OF DIRECTORS.
JURISDICTION AND VENUE
Venue in this court is proper in this Circuit because the cause of action arose in
Honolulu, Hawaii.
FACTS
1. PLAINTIFFS ANGELA KAAIHUE AND YOUNG FRYER is the land-owners of the real property
parcel described as Lot 881-B-5 located at 98-673 Kilinoe St. Aiea. HI. 96701, Tax Map Key No.
(1) 9-8-073-002. Described as undeveloped 82-Acre vacant land parcel, inherited from Land
Developer Herbert Horita.
2. PLAINTIFFS ANGELA KAAIHUE AND YOUNG FRYER purchased the property in 2009.
3. Previous Developers and land owners of same vacant land parcel TMK #9-8-073-002, previously
owned by Herbert Horita, and Wallace Lean NEVER paid any membership dues to the
association.
4. Developer Herbert Horita created and established Newtown Estates and it’s rules, codes, and
covenants.

12. 5. For 30+ years, this parcel remained isolated and outside the developed areas of Newtown.
6. For 30+ years, Herbert Horita owned another property adjacent to lot tmk 9-8-073-002, which
constituted Herbert HOrita a member of Newtown Estates.
7. PLAINTIFFS ANGELA KAAIHUE AND YOUNG FRYER parcel lot remained vacant and undeveloped
for approximately 40 years.
8. This parcel has no condo house, nor apartment, and is vacant land.
9. MDCCR, Article I, Definitions, defines “Owner” (a), shall not include the Declarant with
respect to any “lots” owned by the Declarant. (See Definition of “Lot”, as described in MDCCR,
Aricle 1, Lot.)
The Declarant and Developer Herbert Horita owned this property and maintained it as
undeveloped. PLAINTIFFS ANGELA KAAIHUE AND YOUNG FRYER have inherited developer and
declarant Herbert Horitas rights to develop the 82- Acre of undeveloped vacant land. (MDCCR.
Article 1, Definitions, Owner (a)).
10. MDCCR, Article II, Section 2.02,: Annexation of Subsequent Development (a)(1)(2) (b)(c) The
association may also annex adjacent property upon approval by an affirmative vote of 3/4ths of
all Class A members and by the Class B member, if any, at a meeting duly called for this purpose.
The annexation of such property shall become effective only when declarant or association have
recorded a declaration which consists of more than one document, and declares that such
property is held and shall be held, sold, conveyed, encumbered, leased, occupied, and improved
subject to Newtown Estates Restrictions.
This property fails to consist of such declaration, and has not been annexed.(MDCCR,
Article II, Section 2.02).
It is clearly described in the MDCCR, Article II, of properties subjected to Newtown
Estates Restrictions.
Based on MDCCR, Article II, Section 2.02(a)(1) states that only when MDCCR Section,
2.02(a)(1)(bb) set forth or refer to such additional or other limitations, restrictions, covenants,
and conditions applicable to such property as provided in paragraph (c) ; and (cc) declare that
such property is held and shall be held, sold, conveyed, encumbered, leased, occupied, and
improved subject to NEWTOWN ESTATES Restrictions: . . .
(2) With respect to the real property described in such declaration, Declarant or
Association shall have filed a subdivision map.

13. (b) Upon the annexation becoming effective, the property covered by such
annexation shall become and constitute a part of NEWTOWN ESTATES.
PLAINTIFFS ANGELA KAAIHUE AND YOUNG FRYER vacant land parcel does not meet the criteria, as
their property fails to declare as such stated in MDCCR, Article II, Section 2.02 (a)(1)(cc).
11. MDCCR Article V Section 5.02: Membership (a)- The term owner shall mean an apartment
owner as defined in the Horizontal Property Act (Ch. 514, HRS).
No person other than an Apartment Owner of a lot may be a member of the
Association. PLAINTIFFS ANGELA KAAIHUE AND YOUNG FRYER own vacant land only, they do
not own an apartment as stated by the defined definition of “owner”. (MDCCR, Article V,
Section 5.02).
12. MDCCR Article VII, Section 7.06: Assignment of Powers. Any and all of the rights and powers
voted in the Declarant pursuant to the NEWTOWN ESTATES Restrictions may be delegated,
transferred, assigned, conveyed or released by the Declarant to the Association and the
Association shall accept the same effective upon the recording by the Declarant of a notice of
such delegation, transfer, assignment, conveyance or release.
At no time has Declarant and Developer Herbert Horita or Wallace Lean II transferred
such powers to the association and or the rights, therefore, inherited by PLAINTIFFS ANGELA
KAAIHUE AND YOUNG FRYERS 82-Acre of undeveloped, vacant land property. PLAINTIFFS
ANGELA KAAIHUE AND YOUNG FRYER are unaware of any claims or doings of any assignment
of assigned powers by Declarant’s or their successors to include Declarant’s successors Herbert
Horita, Wallace Lean II, and now comeforth, PLAINTIFFS ANGELA KAAIHUE AND YOUNG FRYER
of property TMK #9-8-073-002 to the DEFENDANTS NEWTOWN ESTATES COMMUNITY
ASSOCIATIONS. (MDCCR, Article VII, Section 7.06: Assignment of Powers).
13. MDCCR, Article VII, Section 7.08: Obligations of Owners, Avoidance, Termination (b).

14. a. Upon the conveyance, sale, assignment, or other transfer of a “lot” (as described in
MDCCR, Article 1) to a new Owner, the transferring Owner shall not be liable for any
assessments levied with respect to such lot and payable after the date of such transfer,
and no person after the termination of his status as an Owner and prior to his again
becoming an Owner shall incur any of the obligations or enjoy any of the benefits of an
Owner under the Newtown Estates Restrictions following the date of such termination.
Therefore, Developer Herbert Horita never acquired membership through this vacant
land parcel, neither previous Developer Wallace Lean, ownership by PLAINTIFFS of such
land parcel cannot be inherited by the new owners or developers, in this case, the
PLAINTIFFS ANGELA KAAIHUE AND YOUNG FRYER. ( MDCCR. Article VII, Sec. 7.08.)
Definition of LOT: as described in MDCCR, Article 1- “Shall mean any lot designated on a subdivision
or development map for residential use, or, with respect to any condominium, an apartment of such
condominium, or, with respect to any townhouse, apartment house, duplex, or multiple dwelling, in law,
medium, or high rise buildings, a complete residential unit, and in each case, except when clearly
contrary to the context, shall include all improvements thereon.” . . .
MDCCR, Article VII, Section 7.10: Reservation to Exclude From the Master Declaration.
b. Declarant reserved the right to exclude from the operation and effect of and the
provisions contained in this Master Declaration. Declarant reserves the right to exclude
from the operation and effect of and the provisions contained in this Master Declaration
those development increments, which are isolated and separated from the rest of the
NEWTOWN ESTATES by its natural features, such as cliffs and streams, so that such part
of the common and recreational areas of NEWTOWN ESTATES, including but not limited
to any lots which may be constructed and developed by Declarant within any Area
identified as Area C designated on the Proposed Newtown Estates Development Plan,
which is separated from the rest of NEWTOWN ESTATES by Waimalu Stream and by the
cliffs next to it.
Therefore, 82- Acre, zoned Preservation, and Apartment, Conservation and
Urban remained as an undeveloped vacant land parcel. It remained undeveloped for
40 years. It consists of cliffs and such stream, specifically named Waimalu River. This
vacant undeveloped land parcel once owned by the Declarant and Real Estate
Developer Herbert Horita and Developer Wallace Lean II has a river which runs
through the property on both sides. Unlike the developed “lots” of Newtown which
consists of residential and apartment homes, to apply the rules of NECA would be

15. incoherent and inapplicable for this multi-zoned vacant land parcel. (MDCCR, Article
VII, Section 7.10: Reservation to Exclude From the Master Declaration).
COUNT I
BAD FAITH
14. PLAINTIFFS ANGELA KAAIHUE AND YOUNG FRYER realleges and incorporates herein by
reference the allegations set forth in Paragraph 1 through 14 above.
15. Initially, PLAINTIFFS ANGELA KAAIHUE AND YOUNG FRYER was told that they were “not a
Part of Newtown”, see Exhibit 1.
16. Initially, PLAINTIFFS ANGELA KAAIHUE AND YOUNG FRYER was told, that to be a part of
Newtown Estates, you would need to be homeowner.
17. Initially, PLAINTIFFS ANGELA KAAIHUE AND YOUNG FRYER were told that, their property
would have to be first annexed by a 2/3 majority vote by the Board of Directors.
18. DEFENDANTS breached its duty of good faith when later it made the decision to oblige the
defendants to the terms and conditions of Newtown and presented with a series of frivolous
false accusations, violations, and fines.
19. DEFENDANTS acted in bad faith when it applied MDCCR of Newtown. Upon doing so, NECA
labeled her as a “bad community standing and member” of Newtown Estates Community and
Association.
20. As a result of DEFENDANTS bad faith, PLAINTIFFS ANGELA KAAIHUE AND YOUNG FRYER have
sustained substantial pain and suffering, and emotional, and physical injury.
COUNT II
UNFAIR AND DECEPTIVE TRADE PRACTICES

16. 21. PLAINTIFF realleges and incorporates herein Paragraphs 1-21 above.
22. NECA is a non-profit organization comprised of a board of directors in the State of Hawaii.
23. NECA engaged in unfair and deceptive practices in violation HRS 480-2, among other things,
providing misleading and incomplete information to members, and directors, providing
incomplete information and failing to inform it’s members of NECA the basis of its default/and
lack of poor judgment.
COUNT III
FAILURE TO PROVIDE ACCURATE INFORMATION
24. PLAINTIFFS ANGELA KAAIHUE AND YOUNG FRYER reallege and incorporates herein
Paragraphs 1-24.
25. Defendants NEWTOWN ESTATES COMMUNITY ASSOCIATION, BY IT’S BOARD OF DIRECTORS,
are well aware of the MDCRRS, and have failed to provide those covenants and codes that
would relieve PLAINTIFFS OF its DUTIES AND OBLIGATIONS, which excludes and exempts their
property from the Newtown Association. Their attempts to apply and misinterpret
segmented rules of their codes and covenants to undeveloped land parcel once owned by
Declarant Herbert Horita is clearly incoherent, frivolous, and malice.
COUNT IV
INFLICTION OF EMOTIONAL DISTRESS
26. PLAINTIFFS ANGELA KAAIHUE AND YOUNG FRYER reallege and incorporate herein Paragraphs
1 though 26 above.

17. 27. As a result of DEFENDANTS NEWTOWN ESTATES COMMUNITY ASSOCIATION BY IT’S BOARD
OF DIRECTORS tortious acts and incoherent, frivolous, and malice, PLAINTIFF’S ANGELA
KAAIHUE AND YOUNG FRYER experienced pain and suffering and a loss of enjoyment of life.
28. PLAINTIFFS ANGELA KAAIHUE AND YOUNG FRYER sustained serious emotional distress and
physical harm as a result of Defendant’s conduct or lack of conduct thereof.
COUNT V
ESTOPPEL
29. PLAINTIFFS ANGELA KAAIHUE AND YOUNG FRYER reallege and incorporate herein Paragraphs
1 though 29 above.
30. DEFENDANTS attempts to misconstrue the rules, codes, and covenants to an incoherent and
inapplicable situation, their attempts to incoherently apply rules to developer and PLAINTIFF
ANGELA KAAIHUE AND YOUNG FRYER, that is inapplicable, incoherent, and disregards their
inherited rights from Developer Herbert Horita’s rights as the Declarant and Developer, clearly
demonstrates malice, is malicious in disguise, and a false claim.
31. DEFENDANTS should be estopped from raising misrepresentations as a defense since Plaintiffs
would suffer substantial prejudice as a result of Defendants untimely assertion of the defense.
COUNT VI
PUNITIVE DAMAGES
32. PLAINTIFFS ANGELA KAAIHUE AND YOUNG FRYER reallege and incorporate herein Paragraphs
1 though 32 above.
33. When the PLAINTIFF ANGELA KAAIHUE AND YOUNG FRYER addressed NECA inquiring about
being a part of the association, the NECA Manager affirmatively defined her role as NOT a

18. member of Newtown. PLAINTIFF ANGELA KAAIHUE AND YOUNG FRYER proceeded to develop
the undeveloped vacant 82- acre land parcel. With approved permits by the City and County
of Honolulu to build and develop a 5000 sq. ft. single family dwelling, PLAINTIFF ANGELA
KAAIHUE AND YOUNG FRYER halted construction costing hundreds of thousands of lost
dollars and time to address the unruly behavior, false allegations, frivolous, malice, and
untimely accusations by DEFENDANTS NEWTOWN ESTATES COMMUNITY ASSOCIATION BY
IT’S BOARD OF DIRECTORS. They later changed their minds, and PLAINTIFF SUBMITTED A
PERMIT TO CONSTRUCT AND APPROVED BY NEWTOWN ESTATES ARCHITECTURAL
COMMITTEE. Shortly thereafter, they cancelled her permit to construct. And frivolous
demands to PLAINTIFF to remove all construction facilities, to include a construction office
trailer, and fenced areas for construction purposes. Their actions were intentional, and they
were fully aware of their doings so that it would result in halting and delaying construction
progress, arising in thousands of tremendous lost costs.
34. Those acts are attributable to DEFENDANTS NEWTOWN ESTATES COMMUNITY ASSOCIATION
BY IT’S BOARD OF DIRECTORS, and ratified the gross misconduct.
35. As a result DEFENDANTS NEWTOWN ESTATES COMMUNITY ASSOCIATION BY IT’S BOARD OF
DIRECTORS should be held liable for punitive damages in an amount to be proven at trial.

19. WHEREFORE PLAINTIFF PRAYS:
A. General and special damages for Plaintiffs ANGELA KAAIHUE AND YOUNG FRYER, in an
amount to be proven at trial;
B. For punitive damages against DEFENDANTS NEWTOWN ESTATES COMMUNITY
ASSOCIATION BY IT’S BOARD OF DIRECTORS, in an amount to be determined at trial.
C. Such equitable relief as the court deems just to make the PLAINTIFFS whole for the
damages suffered herein.
D. For Punitive damages
E. For Costs and Attorney Fees, suits, and interest and such other and further relief as the
Court deems just and proper.
DATED: Honolulu, Hawaii, ________________________, 2013
___________________________________________
ANGELA KAAIHUE and YOUNG FRYER
PRO-SE FOR DEFENDANTS,
AND PLAINTIFF IN CROSS-COMPLAINT

20. IN THE CIRCUIT COURT OF THE FIRST CIRCUIT
STATE OF HAWAII
NEWTOWN ESTATES COMMUNITY CIVIL. NO. 13-1-2161-08 JHC
ASSOCIATION, BY IT’S BOARD OF DIRECTORS (OTHER CIVIL ACTION)
PLAINTIFF,
Vs.
DEMAND FOR JURY TRIAL
ANGELA SUE KAAIHUE; YOUNG NAM FRYER;
JOHN DOES 1-50; JANE DOES 1-50; DOE
PARTNERSHIPS 1-50; DOE CORPORATIONS 1-50;
DOE GOVERNMENTAL AGENCIES 1-50; AND
DOES ENTITIES 1-50,
DEFENDANTS
______________________________________________
DEMAND FOR JURY TRIAL
Defendants ANGELA KAAIHUE, YOUNG NAM FRYER, by and through their own counsel
(Pro-Se), hereby invoke their right to a jury on all issues so triable in this matter.
DATED: Honolulu, Hawaii, _______________________________________
______________________________________
ANGELA S. KAAIHUE
Pro-Se for Defendants
ANGELA KAAIHUE, AND
YOUNG NAM FRYER

21. IN THE CIRCUIT COURT OF THE FIRST CIRCUIT
STATE OF HAWAII
NEWTOWN ESTATES COMMUNITY CIVIL. NO. 13-1-2161-08 JHC
ASSOCIATION, BY IT’S BOARD OF DIRECTORS (OTHER CIVIL ACTION)
PLAINTIFF,
Vs.
CERTIFICATE OF SERVICE
ANGELA SUE KAAIHUE; YOUNG NAM FRYER;
JOHN DOES 1-50; JANE DOES 1-50; DOE
PARTNERSHIPS 1-50; DOE CORPORATIONS 1-50;
DOE GOVERNMENTAL AGENCIES 1-50; AND
DOES ENTITIES 1-50,
DEFENDANTS.
____________________________________________
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a copy of the foregoing document was duly served on the
following by hand delivery on __________________________.
MILTON M. MOTOOKA
KATHERING A. CASWELL
1000 Bishop Street, Suite 801
Honolulu, Hawaii, 96813
Attorneys for Plaintiff
NEWTOWN ESTATES COMMUNITY ASSOCIATION
DATED: Honolulu, Hawaii, _______________________________________
______________________________________
ANGELA S. KAAIHUE
Pro-Se for Defendants
ANGELA KAAIHUE, AND
YOUNG NAM FRYER