This document is a request for entry of default from Angela Sue Kaaihue and Yong Nam Fryer, who are pro se defendants and counter-claim plaintiffs, against Newtown Estates Community Association. It includes affidavits from Kaaihue and Fryer stating that the association failed to respond to their counter-claim within the required time period. It requests a default judgment of $43,450,000 including principal of $40 million, interest, costs and attorney's fees. Exhibits of the filed counter-claim and proofs of service are attached in support of the request.

1. Ms. Angela Sue Kaaihue
Yong Nam Fryer
98-673 Kilinoe St.
Aiea, HI. 96701
(808) 542-9393
Pro-Se Defendant(s)
Pro-Se Counter-Claim Plaintiff(s)
IN THE CIRCUIT COURT OF THE FIRST CIRCUIT
STATE OF HAWAII
NEWTOWNESTATES COMMUNITY ) Civil No. 13-1-2161-08 JHC
ASSOCIATION, by it’s Board of Directors ) (Other Civil Action)
)
Plaintiffs, )
) REQUEST FOR ENTRY OF
) DEFAULT;
) AFFIDAVIT OF ANGELA
) KAAIHUE; AFFIDAVIT OF YONG
) FRYER; C/S
)
ANGELA SUE KAAIHUE; YONG 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, )
_____________________________________________)
ANGELA SUE KAAIHUE; YONG 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 )
)
Counter-Claim Plaintiff(s), )
)
VS., )
)
NEWTOWNESTATES COMMUNITY )
ASSOCIATION, by it’s Board of Directors )
)
Counter-Claim Defendants, )
)
_____________________________________________ )

2. REQUEST FOR ENTRY OF DEFAULT
In this action, the Plaintiff(s)/Counter-Claim Defendant having sued herein for the recovery of
damages in the sum of money, having been personally served with summons and a copy of
complaint, having failed to appear and answer the complaint within the time allowed by law, and
upon application of Defendant’s/Counter-Claim Plaintiffs, default of said Plaintiff’s/Counter-
Claim Defendants having been entered;
Acknowledgement of credit was made in the sum of $20,000,000 to each Co-
Defendant(s)/Counter-Claim Plaintiff(s).
This Request for Entry of Default is made pursuant to District Court Rules of Civil Procedure,
Rule 55(b)(2), and is based upon the attached Declarations, and the records and files herein.
Request for Entry of Default by clerk :
Defendant’s/Counter-Claim Plaintiffs: Angela Sue Kaaihue ($20,000,000) and Yong Nam
Fryer ($20,000,000)
recover from
Plaintiff’s/Counter-Claim Defendants: Newtown Estates Community Association (NECA), by
it’s Board of Directors.
Principal: $ 40,000,000
Interest (Pursuant to Declaration) $ 200,000
Costs $ 2,000,000
Attorney Fees $ 250,000
Total $43,450,000
Defendant’s/Counter-Claim Plaintiffs, Angela Sue Kaaihue and Yong Nam Fryer hereby
requests that an Entry for Default Judgment against Plaintiffs/Counter-Claim Defendants
Newtown Estates Community Associastion (NECA) be granted.

3. __________________________ ___________________________
Date Angela Sue Kaaihue (Pro-Se)
__________________________ ___________________________
Date Yong Nam Fryer (Pro-Se)

4. DECLARATION OF ANGELA SUE KAAIHUE
1. I know the contents and verify that the statements are true to my personal
knowledge and belief. I DECLARE UNDER PENALTY OF PERJURY THAT THE
FOLLOWING IS TRUE AND CORRECT:
2. I am the Co-Defendant/Counter-Claim Plaintiff, as Angela Sue Kaaihue, and submit
this based upon personal knowledge and information from records which have been
maintained and from entries made therein at or near the time of the evens so
recorded.
3. The following facts show why Plaintiff(s)/Counter-Claim Defendant(s) Newtown
Estates Community Association owes the unpaid amounts requested by Co-
Defendant(s)/Counter-Claim Plaintiff(s).
4. On October 23, 2013, I, Angela Sue Kaaihue, filed and served a Counter-Claim. As
of today November 14th, 2018, the Plaintiff(s)/Counter-claim I have not received no
answer to the complaint, or motion or a responsive pleading, has not been filed by
the time fixed by the courts.
5. Attached as EXHIBIT 1, is a true and accurate copy of the Counter-Claim, along
with the documents of service in support of Co-Defendant/Counter-Claim Plaintiff
for judgment filed on October 23, 2013.
6. Attached as EXHIBIT 2, is a true and accurate copy of the Civil Information Sheet
filed on April 12, 2018.
7. Attached as EXHIBIT 3, is a true and accurate copy of the Additional Claims
Information Sheet filed on April 12, 2018.
8. Basedupon my experience as a real estate developer, the amount claimed by
Defendant/Counter-Claim Plaintiff is fair and reasonable.
9. I attest to the fact that service of the counter-claim had been made to the
Plaintiffs/Counter-claim Defendants.

5. 10. I attest to the fact that the Plaintiff’s/Counter-Claim Defendants are not in the
military, juveniles, or incompetent.
11. Defendant/Counter-Claim Plaintiff is not in the military service of the United States
as Defined by the Service Members Civil Relief Act
I, Angela Sue Kaaihue, Declare under penalty of perjury under the laws of the State of
Hawaii, that the foregoing is true and correct.
_______________________ _____________________________
Date Angela Sue Kaaihue

6. DECLARATION OF YONG NAM FRYER
1. I know the contents and verify that the statements are true to my personal
knowledge and belief. I DECLARE UNDER PENALTY OF PERJURY THAT THE
FOLLOWING IS TRUE AND CORRECT:
2. I am the Co-Defendant/Counter-Claim Plaintiff, as Yong Nam Fryer, and submit
this based upon personal knowledge and information from records which have been
maintained and from entries made therein at or near the time of the evens so
recorded.
3. The following facts show why Plaintiff(s)/Counter-Claim Defendant(s) Newtown
Estates Community Association owes the unpaid amounts requested by Co-
Defendant(s)/Counter-Claim Plaintiff(s).
4. On August 13th, 2014, I, Yong Nam Fryer, filed and served a Counter-Claim. As of
today November 14th, 2018, the Plaintiff(s)/Counter-claim I have not received no
answer to the complaint, or motion or a responsive pleading, has not been filed by
the time fixed by the courts.
5. Attached as EXHIBIT 1, is a true and accurate copy of the Counter-Claim, along
with the documents of service in support of Co-Defendant/Counter-Claim Plaintiff
for judgment filed on August 13th 2014.
6. Attached as EXHIBIT 2, is a true and accurate copy of the Civil Information Sheet
filed on April 12, 2018.
7. Attached as EXHIBIT 3, is a true and accurate copy of the Additional Claims
Information Sheet filed on April 12, 2018.
8. Basedupon my experience as a real estate developer, the amount claimed by
Defendant/Counter-Claim Plaintiff is fair and reasonable.
9. Defendant/Counter-Claim Plaintiff is not in the military service of the United States
as Defined by the Service Members Civil Relief Act
10. I attest to the fact that the Plaintiff’s/Counter-Claim Defendants are not in the
military, juveniles, or incompetent.

7. 11. Defendant/Counter-Claim Plaintiff is not in the military service of the United States
as Defined by the Service Members Civil Relief Act
I, Yong Nam Fryer, Declare under penalty of perjury under the laws of the State of
Hawaii, that the foregoing is true and correct.
_______________________ _____________________________
Date Yong Nam Fryer

8. IN THE CIRCUIT COURT OF THE FIRST CIRCUIT
STATE OF HAWAII
NEWTOWNESTATES COMMUNITY ) Civil No. 13-1-2161-08 JHC
ASSOCIATION, by it’s Board of Directors ) (Other Civil Action)
)
Plaintiffs, ) CERTIFICATE OF SERVICE
)
)
)
)
VS, )
)
ANGELA SUE KAAIHUE; YONG 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, )
_____________________________________________)
ANGELA SUE KAAIHUE; YONG 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 )
)
CounterClaim Plaintiff(s), )
)
VS., )
)
NEWTOWNESTATES COMMUNITY )
ASSOCIATION, by it’s Board of Directors )
)
CounterClaim Defendants, )
)
__________________________________________)
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was served via U.S.
mail, postage prepaid, or by hand-delivery at their last known address as follows:

9. Phillip A. Li, Esq.
733 Bishop Street, Ste. 1770
Honolulu, HI. 96813
Attorney for Counterclaim Defendant
Newtown Estates Community Association
Motooka & Rosenberg
1000 Bishop Street, Suite 801
Honolulu, HI., 96813
Attorney for Plaintiff
Newtown Estates Community Association
DATED: Honolulu, Hawaii, November, 14, 2018
_____________________________
ANGELA SUE KAAIHUE
ProSe for Defendant/Counter-Claim Plaintiff
_____________________________
YONG NAM FRYER
ProSe for Defendant/Counter-Claim Plaintiff