This document is Angela Kaaihue's response to the State of Hawaii's motion for reconsideration of a previous court ruling regarding an easement dispute. It summarizes Kaaihue's position that the easement in question, Easement 341, was never designated to anyone and should be cancelled. It notes that WG Minami Inc. and others now have alternative access so their objections to cancelling Easement 341 are moot. Kaaihue has been seeking cancellation of the unused easement for over 5 years and argues the case has been delayed too long. The document requests the court grant Kaaihue's motion to move forward with cancelling Easement 341.

1. MS. ANGELA KAAIHUE
98-673 KILINOEST
AIEA,HI. 96782
Telephone:(808) 542-9393
MS. ANGELA KAAIHUE
IN THE LAND COURT OF THE STATE OF HAWAII
In the Matter of the Application )
Of ) Land Court Application No. 950 (Amended)
) LC Case No 11-1-0271
Edith Austin & Others )
) ANGELA KAAIHUE’S RESPONSE TO MOTION
) FOR RECONSIDERATION FILED DEC. 9, 2016
To register and confirm title to land ) MEMORANDUM BY ANGELA KAAIHUE;NOTICE
) OF HEARING; CERTIFICATE OF SERVICE
Situate at Waimalu, District of Ewa )
City and County of Honolulu, )
State of Hawaii. )
)
) NON-HEARINGANSWER:
) Judge : The Honorable Gary W. B. Chang
________________________________ )
ANGELA KAAIHUE’S RESPONSE TO STATE OF HAWAII’S MOTION FOR
RECONSIDERATION, OR IN THE ALTERNATIVE FOR DISSOLUTION FOR ORDER
GRANTING IN PART AND DENYIN GIN PART “MOTION SEEKING RELIEF FROM WG
MINAMI NON-COMPLIANCE WITH COURT ORDER” FILED ON SEPT. 21, 2016, BY
PETITIONER ANGELA KAAIHUE
Angela Kaaihue moves this Honorable Court to NOT reconsider the State of Hawaii’s
motion for reconsideration, or in the alternative for dissolution of the Court’s previous ruling
Granting in part and Denying in Part “motion Seeking Relief from WG Minami Non-
Compliance with Court Order, filed by myself, Petitioner Angela Kaaihue on Sept. 21, 2016.
This answer is brought pursuant to Rules 7, 59, and 60 of the Hawaii Rules of Civil
Procedure (HRCP) and is based on the memorandum and exhibits attached hereto and the
records and files herein.
Petitioner Angela Kaaihue has by stipulation with the State of Hawai, but not with the
other parties makes this a complicated matter. The stipulation was with the State of Hawaii, and
not with the others, but was somehow over-extended to WG Minami, and Board of Water
Supply. A final map which would show the dissolution of the easement 341 has not been ordered
as stipulated. The State has taken the stance, that it is not their duty to show the “cancellation of
the Easement 341”. Until the compliance with criminal trespassing, criminal harassment,

2. criminal restraining orders, the location and history of the pipe in the road, neighborhood
disputes, acts of racial animosity, and paranoid spying is resolved, then this easement shall NOT
be resolved, which explains the complexity of this case and the “unfairness” to the land –owner
Angela Kaaihue, whom has become the victim of their racial discrimination, and to suggest
taking of Kaaihue’s property without proper and fair compensation, bargaining and negotiating
can NOT be overlooked. The State of Hawaii shares responsibility for co-joindering with WG
Minami Inc, and the Board of Water Supply, in their efforts to obtain a 10 feet easement across
Kaaihue’s property without fair, bargaining and negotiating as WG Minami has done recently
with the recent transaction of Waimalu Holding’s Land parcel and right to an easement. They
simply purchased it for $2 million dollars to secure their right of way across Kaaihue’s property.
Thus presenting the value of their easement to their lands in the back of the Kaaihue’s and the
State’s property.
Keeping in mind, that Easement 341 that Petitioner initially initiated, Angela Kaaihue has
been seeking for the past 5 years was never designated to anyone. If the parties to this case, has
simply honored that fact, then we wouldn’t be in the same situation 5 years later.
DATED: Honolulu, Hawai’I, December 9, 2016

3. IN THE LAND COURT OF THE STATE OF HAWAII
In the Matter of the Application )
Of ) Land Court Application No. 950 (Amended)
) LC Case No 11-1-0271
Edith Austin & Others )
) ANGELA KAAIHUE’S RESPONSE TO MOTION
) FOR RECONSIDERATION FILED DEC. 9, 2016
To register and confirm title to land ) MEMORANDUM BY ANGELA KAAIHUE;NOTICE
) OF HEARING; CERTIFICATE OF SERVICE
Situate at Waimalu, District of Ewa )
City and County of Honolulu, )
State of Hawaii. )
)
) NON-HEARINGANSWER:
) Judge : The Honorable Gary W. B. Chang
________________________________ )
MEMORANDUM IN NON-SUPPORT OF MOTION
Admissible evidence was submitted and presented by no other than Mr. Daniel Morris,
exhibiting a picture of the pipe that was in the center of the easement. An easement has been
established by Honorable Judge Gary W.B. Chang. After years of litigation, an order was to have
to have it surveyed, and although it was not initially staked, it finally was staked, and only 1-side
of the easement was staked demonstrates their elusive character. The pipe had existed prior to the
order of any staking or surveying to help distinguish a 10 feet easement since it was initially
NOT staked, and only surveyed.
The Petitioners motion seeking relief from WG Minami Non-Compliance with Court Order
(Petitioner’s motion0 Or offered at the hearing to establish that the State of Hawaii has violated
the easement rights on the subject parcel by it’s lack of saying anything, and ignorantly driving
outside the boundaries.. This survey was conducted month’s ago, the staking was conducted
months ago, pictures were observed, and taken, and the stake remained in the ground since prior
to the staking.
The State lack of efforts or initiative to address the situation, clearly is a representation of their
“laid back” mentality, in which a legal court case is initiated, to address an easement, but lacks
integrity, lacks the initiative to resolve problems and follow through. Perhaps this is the same

4. kind of mentality, in which why the State of Hawaii had no easement prior for approximately 35
years, and then only 35 years, come out and say, “Oops it was a mistake, the cancellation of
Waimalu Valley Road was a mistake”, the same stance WG Minami Took, as they co-joinder for
an easement that Kaaihue claims may have or may have not been existent with a prior agreement
and landowner Wallace Lean who was the lease-holder for the State of Hawaii, thus he provided
himself access to the lot he leased.
However, it is now apparent, with or without the Honorable Judge Gary Chang’s final execution
of the order for an easement, an eminent domain is to bargain fairly for an easement as it states in
the Hawaii State Constitution. And apparently WG Minami Inc, whom has recently purchased
Waimalu Holdings neighboring and adjacent land parcal, whom has in that deed, runs with the
land, an easement, which makes this nulled proceedings, by WG Minami “wheeling and dealing”
fairly for their easement, unlike with Angela Kaaihue’s case, State of Hawaii and WG Minami,
simply “take” what they think they should take from Angela Kaaihue’s lands. Not only “simply
take” what they think is owed them, but at a cost to Hawaii Tax payers Expense, and to Angela
Kaaihue’s expense, although she is not a licensed attorney, she still demands for 5 years of legal
expenses, and costs, for her time-consumed.
5 years, of legal expenses, for an easement, seemed to present a difficult task for a group of
attorneys, approximately 5 attorneys working effortlessly to obtain an easement, took way to
long, 5 years, plus time is still counting to figure out a simple solution, clearly demonstrates the
inability to successfully develop any land or real estate, only to tie up and litigate, and make up
litigation as in the other case that Angela Kaaihue has been involved in.
A team of attorneys, to rack up bills in attorney costs, worth far more than Kaaihue’s land parcal,
leaves everyone in disarray. Their lack of abilities to communicate, negotiate, and to complete a
simple task, and to make something so small into a mountain, is a complete disgrace to our
Hawaii Tax Payers.
To simply remove the iron pipe, such an easy task, yet so difficult, Kaaihue and her partner
Howard Kim was approached by hostile trespassors WG Minami Inc, by their workers, Faye and
Leslie Nishimura, yelling at them to remove the pipe, yelling and shouting that they now own the
property demonstrates their hateful and bitter personalities, and ignorance, and arrogance, to
claim ownership of land they don’t own, and a clear example of their abuse of this Court’s
authority.
In conclusion, the Court is respectfully asked to NOT reconsider and to NOT dissolve the Courts
Order in this action. Instead, to find WG Minami Inc, and the STATE of HAWAII, furthermore
GUILTY, and to be FOUND Criminal Contempt of Court, for harassment and disorderly
conduct, for harassing I, the petitioner who was following and abiding by the Honorable Judge
Gary Chang’s order to remove the iron pipe. The State clearly knew of this issue, and to remain
ignorant in this matter and the problem that it has initiated, should be held accountable for their
lack of following through, including the Gate that they had promised but had now become

5. LIARS, because there still is NO GATE, and they have no intentions of making a GATE, and in
addition, their malicious actions to now Prohibit Kaaihue from entering her own property by the
GATE that has been erected further down the road by WG Minami across STATE property, or
now it has been quit-deeded to WG Minami Inc by another fraud transaction claiming that an old
Hawaiian railway was deeded to WG Minami Inc, and NOT the property of the STATE. This
clearly further exasperates the problem that is trying to be resolved here.
May the Honorable Judge find the matter of this case difficult, as Angela Kaaihue needs to
address multiple parties involved in this case, and at times treat them simultaneously alike, but in
this occurrence, differently? This makes the case even harder to address, and determine, who is
who, which is which.
DATE: Honolulu, Hawaii, December 12, 2016
_______________________________________
ANGELA KAAIHUE
LANDOWNER

6. MS. ANGELA KAAIHUE
98-673 KILINOEST
AIEA,HI. 96782
Telephone:(808) 852-9663
MS. ANGELA KAAIHUE(Pro-se)
IN THE LAND COURT OF THE STATE OF HAWAII
In the Matter of the Application )
)
Of ) Land Court Application No. 950 (Amended)
)
Edith Austin & Others ) LC Case No. 11-1-0271
)
To register and confirm title to land )
Situate at Waimalu, District of Ewa, ) DECLARATION OF ANGELA KAAIHUE
City and County of Honolulu, )
)
State of Hawaii. )
________________________________ )
DECLARATION OF ANGELA KAAIHUE
1. I, ANGELA KAAIHUE, MOTION TO MOVE FORWARD WITH PETITION THIS
COURT TO CANCEL EASEMENT 341
2. ALTHOUGH EASEMENT 341 WAS ESTABLISHED IN 341, IT WAS NEVER
ASSIGNED TO ANYONE, IT HAS NOT BEEN USED EXCEPT FOR A 10 FEET
SECTION WIDE, AND 60 FEET LONG PAVED ASPHALT ROAD.
3. SINCE JANUARY 27, 2011, THE PETITION TO CANCEL 341 HAS BEEN
DELAYED NUMEROUSLY MEANWHILE, WG MINAMI INC, STATE OF
HAWAII, BOARD OF WATER SUPPLY HAS BEEN GRANTED A 10 FEET WIDE
EASEMENT TO ACCESS THEIR PROPERTIES OVER AND ACROSS LAND
PARCEL KNOWN AS WAIMALU VALLEY ACCESS ROAD. SO THEIR
ORIGINAL CONCERNS AND OBJECTIONS ABOUT CANCELLING EASEMENT
341 HAS BEEN ADDRESSED.
4. WG MINAMI, AKA SFA ENTERPRISES, NOW OWN WAIMALU HOLDINGS,
AND THE OPTION AGREEMENT, IN ADDITION A GRANT OF EASEMENT, SO
WG MINAMI INC HAS ACQUIRED THEIR ACCESS THROUGH OTHER MEANS,
THEY CAN NOW SELF- GRANT THEIR OWN EASEMENT TO WG MINAMI INC.

7. 5. I BEGAN THIS PETITION IN JAN. OF 2011, MORE THAN 5 YEARS AGO. I CAN’T
IMAGINE TRYING TO ACCOMPLISH ANYTHING MORE COMPLICATED THAN
A SIMPLE EASEMENT.
6. I AM SEEKING CANCELLATION OF EASEMENT 341, APPROXIMATELY 60
FEET WIDE, WHICH IS NOT USED, OTHER THAN A 10 FEET
7. I AM REQUESTING THAT MY MOTION TO MOVE FORWARD TO PETITION TO
CANCEL EASEMENT 341 TO BE GRANTED.
8. EVIDENCE WAS PROVIDED BY MR. DANIEL MORRIS HIMSELF, WITH THE
PRESENTATION OF EVIDENCE IN HIS OWN HANDS, A PICTURE OF THE PIPE
IN THE MIDDLE OF THE EASEMENT. ONE’S OWN LOGICAL REASONING IS
ENOUGH EVIDENCE THAT IF THE ROAD IS BEING USED TO ACCESS THE
BOARD OF WATER SUPPLY, THEN THE ONLY WAY TO ENTER THE ROAD IS
BY DRIVING AROUND THE BOUNDARIES OF THE 10 FEET EASEMENT.
9. “I HAVE NO KNOWLEDGE, OR THIS IS NOT THE SCOPE OF OUR PROBLEM” IS
THERE REOCCURING ANSWERS IN SOLVING PROBLEMS OR ISSUES, AS
CINDY YOUNG HAD STATED NUMEROUSLY BEFORE.
10. CINDY YOUNG HAD PROMISED WITH THE OTHER PARTIES, TO INSTALL A
GATE, TO THIS DAY, THERE HAS BEEN NO FURTHER DISCUSSION, OR ANY
HOPES OF A GATE INSTALLED, INSTEAD, HOWEVER, THEY INSTALLED A
GATE ON STATE PROPERTY BY WG MINAMI IN, LOCKING ANGELA
KAAIHUE OUT OF HER OWN PROPERTY.
11. LACK OF ANY EMPOWERMENT IN THIS CASE, PUTS ANGELA KAAIHUE, AT
A DISADVANTAGE, AND THE CAUSE OF THESE UNRULY, MALICIOUS
CONTINUOUS ACTS OF TERRORISM.
I HEREBY DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING
STATEMENTS ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE
AND BELIEF.
DATED: HONOLULU, HAWAI’I, DECEMBER 9, 2016.
___________________________________
ANGELA S. KAAIHUE

9. MS. ANGELA KAAIHUE
98-673 KILINOEST
AIEA,HI. 96782
Telephone:(808) 852-9663
MS. ANGELA KAAIHUE
IN THE LAND COURT OF THE STATE OF HAWAII
In the Matter of the Application )
)
Of ) Land Court Application No. 950 (Amended)
)
Edith Austin & Others ) LC Case No. 11-1-0271
)
To register and confirm title to land )
Situate at Waimalu, District of Ewa, ) CERTIFICATE OF SERVICE
City and County of Honolulu, )
)
State of Hawaii. )
________________________________ )
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing Ms. Angela Ka’aihue
MOTION TO MOVE FORWARD WITH PETITION FOR: CANCELLATION OF
EASEMENT 341; MEMORANDUM OF ANGELA KAAIHUE; NOTICE OF HEARING
was duly served upon the following parties, by causing said copies to be mailed by
United States Mail, first-class postage pre-paid, to their last known address:
Rush Moore LLP City and County of Honolulu
Stephen K.C. Mau, Esq. Board of Water Supply
737 Bishop Street, Suite 2400 Burt Lau, ESQ.
Honolulu, Hawaii, 96813 Joseph A. Stewart, ESQ
Kobayashi, Sugita, and Goda
Attorneys for SFA Enterprises, LLC . 999 Bishop Street, Suite 2600
Honolulu, HI. 96813
MICHAEL H. LAU, ESQ
Morihara Lau, & Fong LLP
841 Bishop St. Suite 400
Honolulu, Hi. 96813
Attorneys for WG Minami Inc.

10. KAREN HOLMA, ESQ.
Bays Lung Rose, and Holma
Topa Financial Center
700 Bishop Street, Suite 900
Honolulu, Hi. 96813
Reid K. Siarot
State Surveyor
1151 Punchbowl Street, Room 210
Honolulu, hI. 96813
Nicki Ann Thompson
Registrar
1151 Punchbowl Street, Room 121
Honolulu, HI. 96813
David M. Louis, Esq.
Cindy Y. Young, Esq.
DAG
465 South King St. Rm #300
Honolulu, Hawaii 96813
Attorneys for State of Hawaii
YONG NAM FRYER
98-673 Kilinoe St.
Aiea, HI. 96701
DATED: Honolulu, Hawai’I, _______________________________________________
___________________________________
Ms. Angela Ka’aihue