Grassroot complaint

Ad

Ad

Ad

Ad

Ad

Ad

Ad

Ad

Ad

Ad

Ad

Ad

NING LILLY & JONES
MICI{AEL A. LILLY #1681
707 Richards Street, Suite 700
Honolulu, Hawaii 96813
Email: Michael@nljlaw.com...

Affairs, in his official Capacity; JOHN D.
WAIHE'E III, Chairman, Native Hawaiian
Roll Commission, in his official
Capacit...

the U.S. Constitution, including the Equal Protection Clause of the Fourteenth
Amendment, the Fifteenth Amendment, the Fir...

PARTIES
6. PlaintiffKeli'i Akina is a citizen and a resident of the State of Hawaii,
and a registered voter. He is a desce...

Advertisement

10. Plaintiff Pedro Kana'e Gapero is a citizen and resident of the State of
Hawaii, and a registered voter. He is a descen...

cooperating with it in the performance of its duties. ,See Act 195, 201 I Legislative
Session (codified in chapter 10H, Ha...

capacities.
18. Defendant The Akamai Foundation ("4F") is, on information and
belief, a 501(cX3) nonprofit organization ex...

or are in some manner presently unknown to Plaintiffs or their attomeys engaged or
involved in the activities alleged here...

held in a "public trust" for certain specified purposes. Hawaii Statehood
Admission Act of March 18, 1959, Pub. L. No. 86-...

Advertisement

by Hawaii law as "any descendant of the aboriginal peoples inhabiting the
Hawaiian Islands which exercised sovereignty and...

29. Act 195 provides that the "purpose of this chapter is to provide t'or
and to implement the recognition of the Native H...

ancestry requirements of Kamehameha Schools or of any Hawaiian registry
program of the office of Hawaiian affairs."
33. Ac...

"SIGN TFIE PETTTTON (EVERYONE)."
40. Selecting "SIGN Tm PETITION (EVERYONE)" does not allowthe
option of registering for t...

1778, or a person who is eligible for the programs of the Hawaiian Homes
Commission Act, 1920, or a direct lineal descenda...

Advertisement

satis¡/ the veriflcation-of-ancestry checklist.
47. Plaintiffs Kent and Mitsui could not confirm any of the declarations,
...

tasks and describing the use of the entire grant amount described in the Grant
Agreement.
51. On or about May 7 and 8,2015...

and written by Christine Donnelly, apparently based on conversations with
representatives of NAF, the following schedule w...

58. As reflected in the written minutes of OHA's Board of Trustees'
meeting of February 26,20t5, "Trustee Ahu Isa question...

61. The NHRC was established under Hawaii law by Act 195 for a public
pu{pose, and received its funding from OHA (Act 195,...

Advertisement

goal of our efforts is to facilitate a process that gives Hawaiians the
opportunity to re-develop a government that reffir...

67. On the NHRC website, virtually every page contains some expression
of support for the purposes of Act 195.
68. Private...

provided such covert encouragement that AF's and NAF's choices should be
deemed those of the State of Hawaii.
75. A privat...

CLAIMS
Claims Allegins Race-Based Restrictions and OualifÎcations Relating to
Votins
COUNT 1: Violation of the Fifteenth A...

COUNT 2: Violation of the Equal Protection Clause of the
Fourteenth Amendment and 42 U.S.C. S 1983.
85. Plaintiffs incorpo...

Advertisement

$account ofrace or color." 92. Act 195 and the registration process used by the defendants restrict who may register for th...$

98. As a practical matter, requiring confirmation of this statement will
stack the electoral deck, guaranteeing that Roll ...

Plaintiffs Akina and Makekau under the Fourteenth Amendment to the equal
protection of the laws.
Claims Allegins Race-Base...

1 1 1. The disqualiflrcation of candidates based on race is conduct
undertaken under color of Hawaii law.
1 I 2. The disqu...

118. Declaration Two, which is part of the registration process available on
the NHRC's website, requires an applicant to ...

Advertisement

Claim Allesins Impairment of Fundamental Right to Vote
COIINT 8: Violation of the Due Process Clause of the Fourteenth
Ame...

13I. Forcibly registering an individual amounts to compelled speech.
132. In addition, forcibly registering an individual ...

relating to the Roll violate the U.S. Constitution and federal law, as set forth above;
2. Issue preliminary and perma¡ent...

7. Award Plaintifß any and all flrther relief that this Court deems just
and proper.
DATED: Honolulu, Hawaii, August 13.20...

Share Slideshare

LinkedIn
Facebook
Twitter

Embed

Size (px)

Show related Slideshows at end

WordPress Shortcode

Link

LinkedIn
Facebook
Twitter
Email

Replay

View on Slideshare

1 of 33 Ad

View on Slideshare

1 of 33 Ad