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ERIC A. SEITZ
ATTORNEY AT LAW
A LAW CORPORATION
ERIC A. SEITZ
1412
DELLA A. BELATTI
7945
SARAH R. DEVINE
9673
820 Mililani Street, Suite 714
Honolulu, HI 96813
Telephone: (808) 533-7434
Facsimile: (808) 545-3608
Attorneys for Plaintiffs
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF HAWAII
GULSTAN E. SILVA, JR., as
Personal Representative of the
Estate of Sheldon Paul Haleck;
JESSICA Y. HALECK, Individually
and as Guardian Ad Litem of
JEREMIAH M.V. HALECK; WILLAM E.
HALECK; and VERDELL B. HALECK,

)
)
)
)
)
)
)
)
Plaintiffs,
)
)
Vs.
)
)
CITY AND COUNTY OF HONOLULU;
)
DONNA Y.L. LEONG, Individually )
and in her Official Capacity;
)
LOUIS M. KEALOHA, Individually )
and in his Official Capacity;
)
CHRISTOPHER CHUNG; SAMANTHA
)
CRITCHLOW; STEPHEN KARDASH; and )
JOHN and/or JANE DOES 1-10,
)
)
Defendants.
)
)

CIVIL NO. 15-00436
COMPLAINT FOR DAMAGES; DEMAND
FOR JURY TRIAL

COMPLAINT FOR DAMAGES
Plaintiffs GULSTAN E. SILVA, JR., as Personal
Representative of the Estate of Sheldon Paul Haleck, JESSICA Y.
HALECK, Individually and as Guardian Ad Litem of JEREMIAH M.V.

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HALECK, WILLIAM E. HALECK, and VERDELL B. HALECK, by and through
their undersigned attorneys, allege as follows:
I.
(1)

Introduction

This is an action to redress the deprivation under

color of statutes, ordinances, rules, regulations, customs,
policies, practices, and/or usages of rights, privileges, and
immunities secured to Sheldon Paul Haleck by the Fourth and
Fourteenth Amendments to the Constitution of the United States,
inter alia, Article I, Sections 5, 6, and 7, of the Constitution
of the State of Hawaii, inter alia, and 42 U.S.C. Section 1983,
et seq.
(2)

Plaintiffs contend that Sheldon Paul Haleck was

wrongfully seized, denied his liberty, and fatally assaulted by
Defendants CHUNG, CRITCHLOW, KARDASH, and/or JOHN and/or JANE
DOES 1-10 in violation of applicable provisions of the
Constitution of the United States and the Constitution of the
State of Hawaii, inter alia.
(3)

Plaintiffs contend that Defendants LEONG and

KEALOHA, and/or JOHN and/or JANE DOES 1-10 have deliberately
withheld information from Plaintiffs and the public and
affirmatively acted to cover up and distort the true facts and
circumstances relating to the death of Sheldon Paul Haleck.
II.
(4)

Jurisdiction and Venue

This case arises under the Constitution and

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statutes of the United States of America and the State of Hawaii,
inter alia.
(5)

The claims asserted herein present a question of

federal law thereby conferring jurisdiction upon the Court
pursuant to 28 U.S.C. Sections 1331, 1343(3), 2201 and 2202, and
42 U.S.C. Section 1983, inter alia.

Any and all state law claims

contained herein form part of the same case or controversy as
gives rise to Plaintiffs’ federal law claims and therefore fall
within the Court’s supplemental jurisdiction pursuant to 28
U.S.C. Section 1367.
(6)

Venue resides in the United States District Court

for the District of Hawaii pursuant to 28 U.S.C. Section 1391(b),
inter alia, as all of the events and/or omissions described
herein occurred in the State of Hawaii.
III. Parties
(7)

Sheldon Paul Haleck (hereinafter “Sheldon”) was a

resident of the City and County of Honolulu, State of Hawaii, at
all times pertinent hereto.
(8)

Plaintiff GULSTAN E. SILVA, JR., is the natural

uncle and Personal Representative of the Estate of Sheldon Paul
Haleck and has been a resident of the City and County of
Honolulu, State of Hawaii, at all times pertinent hereto.
(9)

Plaintiff JESSICA Y. HALECK is the wife of Sheldon

and Guardian Ad Litem of JEREMIAH M.V. HALECK and has been a

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resident of the City and County of Honolulu, State of Hawaii, at
all times pertinent hereto.
(10) JEREMIAH M.V. HALECK is the minor son of Sheldon
and Jessica Y. Haleck and has been a resident of the City and
County of Honolulu, State of Hawaii, at all times pertinent
hereto.
(11) WILLIAM E. HALECK is the natural father of Sheldon
and has been a resident of the State of Utah at all times
pertinent hereto.
(12) VERDELL B. HALECK is the natural mother of Sheldon
and has been a resident of the State of Utah at all times
pertinent hereto.
(13) Defendant CITY AND COUNTY OF HONOLULU is and has
been a duly organized municipal corporation of the State of
Hawaii at all times pertinent hereto.
(14) Defendant DONNA Y.L. LEONG (hereinafter “Defendant
LEONG”) is and has been a citizen and resident of the City and
County of Honolulu, State of Hawaii, and is and has been the
Corporation Counsel for the City and County of Honolulu at all
times pertinent hereto.

Defendant LEONG is sued herein in her

individual and official capacities.
(15) Defendant LOUIS M. KEALOHA (hereinafter “Defendant
KEALOHA”) is and has been a citizen and resident of the City and
County of Honolulu, State of Hawaii, and is and has been the

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Chief of the Honolulu Police Department at all times pertinent
hereto.

Defendant KEALOHA is sued herein both in his individual

and official capacities.
(16) Plaintiffs are informed and believe, and thereupon
allege, that Defendant CHRISTOPHER CHUNG (hereinafter “Defendant
CHUNG”) is and has been a citizen and resident of the City and
County of Honolulu, State of Hawaii, and is and has been employed
as a police officer by the Honolulu Police Department at all
times pertinent hereto.

Defendant CHUNG is sued herein both in

his individual and official capacities.
(17) Plaintiffs are informed and believe, and thereupon
allege, that Defendant SAMANTHA CRITCHLOW (hereinafter “Defendant
CRITCHLOW”) is and has been a citizen and resident of the City
and County of Honolulu, State of Hawaii, and is and has been
employed as a police officer by the Honolulu Police Department at
all times pertinent hereto.

Defendant CRITCHLOW is sued herein

both in her individual and official capacities.
(18) Plaintiffs are informed and believe, and thereupon
allege, that Defendant STEPHEN KARDASH (hereinafter “Defendant
KARDASH”) is and has been a citizen and resident of the City and
County of Honolulu, State of Hawaii, and is and has been employed
as a police officer by the Honolulu Police Department at all
times pertinent hereto.

Defendant KARDASH is sued herein both in

his individual and official capacities.

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(19) Defendants JOHN and/or JANE DOES 1-10 (hereinafter
“DOE DEFENDANTS”) are individuals whose true identities and
capacities are as yet unknown to Plaintiffs and their counsel,
despite diligent inquiry and investigation, and who acted herein
as described more particularly below in connection with the
breaches of duties and/or violations of law alleged herein and
who in some manner or form not currently discovered or known to
Plaintiffs may have contributed to or be responsible for the
wrongful death and injuries alleged herein.

The true names and

capacities of DOE DEFENDANTS will be substituted as they become
known.

DOE DEFENDANTS are sued herein both in their individual

and official capacities.
IV.

Factual Allegations

(20) On or about March 16, 2015, at or about 8:16 pm,
Sheldon was at or near the intersection of South King Street and
Richards Street in Honolulu, Hawaii.
(21) At or about 8:16 pm, for reasons unknown to
Plaintiffs, Defendant Officers CHUNG, CRITCHLOW, KARDASH, and
other unnamed DOE DEFENDANTS arrived at or near the intersection
of South King Street and Richards Street, confronted Sheldon, and
began questioning him.
(22) Plaintiffs are informed and believe, and thereupon
allege, that as Sheldon was talking to Defendant Officers, for
reasons unknown to Plaintiffs and without warning to Sheldon,

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Defendant CRITCHLOW deployed her Taser which struck Sheldon in
his chest.
(23) After being struck by Defendant CRITCHLOW’s
initial Taser discharge, Sheldon attempted to back away from
Defendant Officers as Defendant Officers continued to pursue him.
(24) Sheldon turned away and attempted to walk away
from Defendant Officers when Defendant CRITCHLOW deployed her
Taser a second time, this time striking Sheldon in his back.
(25)

After being struck a second time, Sheldon fell to

his back on the ground along South King Street.
(26) Defendants CHUNG, CRITCHLOW, KARDASH, and/or other
unnamed DOE DEFENDANTS then physically assaulted Sheldon as he
lay on the ground on his back.
(27) Defendant Officers flipped Sheldon on to his
stomach, restraining him on the ground for several minutes.
(28) An unidentified officer then assaulted and
restrained Sheldon by violently and forcefully planting his knee
on to and across Sheldon’s neck and upper back while other
officers restrained and cuffed Sheldon’s hands and legs.
(29) Plaintiffs are informed and believe, and thereupon
allege, that Sheldon was dragged along the road to the sidewalk
by Defendant Officers CHUNG, CRITCHLOW, KARDASH, and/or certain
of the DOE DEFENDANTS.

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(30)

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Plaintiffs are informed and believe, and

thereupon allege, that Sheldon sustained injuries including but
not limited to loss of consciousness, punctures to his chest and
back, abrasions to his right forehead, right cheekbone, both
feet, both knees, and inner left ankle, and swelling of both
hands and both feet.
(31) Plaintiffs are informed and believe, and thereupon
allege, that no officer ever warned Sheldon that a Taser would be
deployed prior to the first or second deployment of Defendant
Officer CRITCHLOW’s Taser.
(32) Plaintiffs are informed and believe, and thereupon
allege, that no officer announced to Sheldon that he was under
arrest prior to the first or second deployment of Defendant
Officer CRITCHLOW’s Taser.
(33) Sheldon was unarmed at all times pertinent hereto.
(34) Sheldon was not threatening members of the public
or any of the Defendants at all times pertinent hereto.
(35) Sheldon was not actively resisting or threatening
Defendants CHUNG, CRITCHLOW, KARDASH and/or any DOE DEFENDANTS at
all times pertinent hereto.
(36) At or about 8:30 pm, Sheldon was arrested for
disorderly conduct pursuant to HRS Section 711-1101.
(37) Some time after 8:50 pm, Sheldon was taken to
Queen’s Medical Center for treatment of his injuries that were a

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direct and proximate cause of being shot with the Taser and
assaulted by Defendants CRITCHLOW, CHUNG, KARDASH, and/or other
DOE DEFENDANTS.
(38) As a result of the actions of Defendants CHUNG,
KARDASH, CRITCHLOW, and/or other DOE DEFENDANTS, Sheldon suffered
fatal injures and died on Tuesday, March 17, 2015, at or about
7:33 am.
(39) Sheldon did not at any time provoke, invite,
consent to, or otherwise allow or permit Defendants CHUNG,
CRITCHLOW, KARDASH and/or DOE DEFENDANTS to touch, seize, or
assault him.
(40) Plaintiffs are informed and believe, and thereupon
allege, that all of the individually named Defendant Officers and
DOE DEFENDANTS were instructed pursuant to the Honolulu Police
Department’s Policy Number 1.04 entitled “Use of Force.”
(41) Plaintiffs are informed and believe, and thereupon
allege, that Defendant KEALOHA ratified Policy Number 1.04.
(42) Pursuant to Policy Number 1.04, individual
Defendant Officers are permitted to “use reasonable force to
effectively bring an incident under control” and are “restricted
to the use of force that is “objectively reasonable” in light of
the facts and circumstances as the officer perceived them to be
at the time of the incident.”

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(43) The Honolulu Police Department’s Policy Number
1.04 prohibits the use of unreasonable or excessive force, in
relevant part, as follows:
“Unreasonable force is not justified or condoned by the
department. Unreasonable force is defined as the use
of force which is not reasonable or justifiable by the
circumstances of the particular event. The use of
force need not be excessive to be deemed unreasonable,
as in situations that do not require any use of force.
…
Excessive force is not justified or condoned by the
department. Excessive force is defined as the amount
of force which is beyond the need and circumstances of
the particular event, or which is not justified in the
light of all the circumstances.”
(44) Plaintiffs are informed and believe, and thereupon
allege, that the above described actions of Defendants CHUNG,
CRITCHLOW, KARDASH and/or DOE DEFENDANTS were without reasonable,
just, and/or probable cause.
(45)

As a direct and proximate result of the

foregoing, Sheldon suffered traumatic and fatal injuries, great
physical and mental pain, anguish and suffering, severe emotional
distress, anxiety, embarrassment, humiliation, worry and anger.
(46) As a direct and proximate result of the foregoing,
Sheldon required medical treatment in amounts to be proven at
trial.
(47) As a direct and proximiate result of the
foregoing, Sheldon suffered loss of earnings in amounts to be
proven at trial.

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(48) As a direct and proximate result of the foregoing
Plaintiffs have suffered great mental pain, anguish and
suffering, severe emotional distress, anxiety, embarrassment,
humiliation, worry and anger.
V.
First Cause of Action
(Fourth Amendment and/or
42 U.S.C. Section 1983 Violations)
(49) Plaintiffs hereby incorporate all of the
allegations contained in Paragraphs 1 through 48 above.
(50) Plaintiffs are informed and believe, and thereupon
allege, that Defendants CHUNG, CRITCHLOW, KARDASH and/or DOE
DEFENDANTS acted and/or purported to act herein under color of
statutes, ordinances, rules, regulations, customs, policies,
practices, and/or usages of the City and County of Honolulu,
State of Hawaii, and in the scope and course of their employment
as police officers in the Honolulu Police Department.
(51) Plaintiffs are informed and believe, and thereupon
allege, that Sheldon was seized and assaulted and suffered the
loss of his life and liberty without any probable, sufficient,
just, or reasonable cause in violation of rights guaranteed to
him by the Fourth Amendment to the United States Constitution,
and Article I of the Constitution of the State of Hawaii, inter
alia.
(52) As a direct and proximate result of the actions of
Defendants CHUNG, CRITCHLOW, KARDASH, and/or certain other DOE

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DEFENDANTS, Sheldon sustained substantial damages in amounts to
be proven at trial.
VI. Second Cause of Action
(Fourteenth Amendment and/or
42 U.S.C. Section 1983 Violations)
(53) Plaintiffs hereby incorporate all of the
allegations contained in Paragraphs 1 through 48, and 50 through
52 above.
(54) Defendants CHUNG, CRITCHLOW, KARDASH, and/or
certain other DOE DEFENDANTS knew, or should have known that
their actions were unreasonable and/or excessive and violated
Sheldon’s clearly established constitutional rights.
(55) Defendants CHUNG, CRITCHLOW, KARDASH and/or
certain other DOE DEFENDANTS were deliberately indifferent to
Sheldon’s clearly established constitutional rights and acted
with a purpose to harm Sheldon unrelated to legitimate lawenforcment objectives.
(56) JEREMIAH M.V. HALECK has directly and proximately
suffered the loss of companionship and society of his father
without any probable, sufficient, just, or reasonable cause.
(57) WILLIAM E. HALECK and VERDELL B. HALECK have
directly and proximately suffered the loss of companionship and
society of their son without any probable, sufficient, just, or
reasonable cause.

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(58) As a direct and proximate result of the foregoing,
Plaintiffs JEREMIAH M.V. HALECK, WILLIAM E. HALECK, and VERDELL
B. HALECK sustained substantial damages in amounts to be proven
at trial.
VII. Third Cause of Action
(Constitutional and/or 42 U.S.C. Section 1983
Violations: Municipal Liability)
(59) Plaintiffs hereby incorporate all of the
allegations contained in Paragraphs 1 through 48, and 50 through
52.
(60) Plaintiffs allege that it is the policy, practice,
and custom of Defendant KEALOHA, the Honolulu Police Department,
its supervisors, and police officers to tolerate and ratify the
use of unreasonable and/or excessive uses of force by its police
officers, employees, and/or agents.
(61) Plaintiffs are informed and believe, and thereupon
allege, that despite the clear prohibitions against excessive and
unreasonable force contained in Policy Number 1.04, Defendants
CHUNG, CRITCHLOW, KARDASH, and/or certain other DOE DEFENDANTS
were not adequately trained, investigated, supervised,
disciplined, and/or retrained by Defendants KEALOHA and CITY AND
COUNTY OF HONOLULU in the use of Tasers and other means of force.
(62) As a direct and proximate result of the foregoing,
Sheldon sustained substantial damages in an amount to be proven
at trial.

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VIII. Fourth Cause of Action
(Assault and Battery)
(63) Plaintiffs hereby incorporate all of the
allegations contained in Paragraphs 1 through 48 above.
(64) Defendants CHUNG, CRITCHLOW, KARDASH, and/or DOE
DEFENDANTS acted herein outside the scope of their employment as
police officers with the Honolulu Police Department.
(65) Plaintiffs are informed and believe, and thereupon
allege, that Defendants CHUNG, CRITCHLOW, KARDASH, and/or certain
DOE DEFENDANTS intentionally, willfully, knowingly, malicously,
and deliberately assaulted and attacked Sheldon without
provocation and/or lawful justification.
IX. Fifth Cause of Action
(Intentional Infliction of Emotional Distress)
(66)

Plaintiffs hereby incorporate all of the above

allegations contained in Paragraphs 1 through 48, 64 and 65
above.
(67) Plaintiffs are informed and believe, and thereupon
allege, that Defendants CHUNG, CRITCHLOW, KARDASH, and/or DOE
DEFENDANTS maliciously, knowingly, intentionally, willfully,
deliberately, and without regard for the rights, interests, and
well-being of Sheldon, proximately caused Plaintiffs to suffer
severe emotional distress in amounts to be proven at trial.

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X.

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Sixth Cause of Action
(Negligence Claims)

(68) Plaintiffs hereby incorporate all of the
allegations contained in Paragraphs 1 through 48 above.
(69) Plaintiffs are informed and believe, and thereupon
allege, that Defendants CHUNG, CRITCHLOW, KARDASH, and/or DOE
DEFENDANTS acted herein negligently thereby proximately and
directly causing Sheldon to suffer physical injuries, pain,
mental anguish, severe emotional distress, anxiety,
embarrassment, humiliation, worry, and anger in amounts to be
proven at trial.
(70) Plaintiffs are informed and believe, and thereupon
allege, that Defendants CHUNG, CRITCHLOW, KARDASH, and/or DOE
DEFENDANTS proximately and directly caused Plaintiff JESSICA
HALECK, individually, to suffer loss of companionship, comfort,
consortium, protection, marital care, attention, advice, and
counsel from her husband, Sheldon, in amounts to be proven at
trial.
(71) Plaintiffs are informed and believe, and thereupon
allege, that Defendants CHUNG, CRITCHLOW, KARDASH, and/or DOE
DEFENDANTS proximately and directly caused JEREMIAH M.V. HALECK
to suffer loss of companionship, comfort, protection, and
parental care from his father, Sheldon, in amounts to be proven
at trial.

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(72) Plaintiffs are informed and believe, and thereupon
allege, that Defendants CHUNG, CRITCHLOW, KARDASH, and/or DOE
DEFENDANTS proximately and directly caused Plaintiffs WILLIAM
HALECK and VERDELL B. HALECK to suffer loss of companionship,
comfort, protection, and loss of filial care and attention from
their son, Sheldon, in amounts to be proven at trial.
XII. Eighth Cause of Action
(Negligent Infliction of Emotional Distress)
(73) Plaintiffs hereby incorporate all of the
allegations contained in Paragraphs 1 through 48, 69 through 72
above.
(74) Plaintiffs are informed and believe, and thereupon
allege, that Defendants negligently caused Sheldon to suffer
mental anguish, severe emotional distress, anxiety,
embarrassment, humiliation, worry, and anger in amounts to be
proven at trial.
(75) Defendants CHUNG, CRITCHLOW, KARDASH, and/or DOE
DEFENDANTS’ actions herein were committed within the scope of
their employment by Defendants CITY AND COUNTY OF HONOLULU and
KEALOHA as Honolulu police officers.
XIV. Tenth Cause of Action
(Interference with Civil Rights)
(76) Plaintiffs hereby incorporate all of the
allegations contained in Paragraphs 1 through 48, 50 through 52,
54 through 57, and 60 through 62 above.

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(77) Plaintiffs made numerous oral requests for police
reports and documents pertaining to the Honolulu Police
Department’s interactions with Sheldon on March 15 and 16, 2015,
and records, including Sheldon’s autopsy report.
(78) On or about May 13, 2015, Plaintiffs requested, in
writing, from Defendant KEALOHA the police reports, radio
transmissions, documents, or records pertaining to Honolulu
Police Department interactions with Sheldon on March 15 and 16,
2015.
(79) On or about May 27, 2015, Defendant KEALOHA denied
Plaintiffs the requested documents because “[t]he documents
requested are part of an ongoing investigation and production
would constitute a frustration of government purpose pursuant to
Section 92F-13(3), Hawaii Revised Statues.”
(80) Defendant KEALOHA further denied Plaintiffs the
requested documents because the documents “are protected by
Section 92F-14, Hawaii Revised Statutes.”
(81) On or about June 5, 2015, Plaintiffs requested, in
writing, a copy of the Honolulu Medical Examiner’s autopsy report
related to Sheldon.
(82) Plaintiffs’ request was denied by the Honolulu
Medical Examiner because the Honolulu Medical Examiner needed to
receive clearance from Defendant CITY AND COUNTY OF HONOLULU and
its agencies, including but not limited to the Honolulu Police

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Department and the Department of the Prosecuting Attorney.
(83) On June 9, 2015, Plaintiffs requested from
Defendant LEONG, in writing, a copy of the Medical Examiner’s
autopsy report, death certificate, all police reports, radio
transmissions, and other documents or records pertaining to the
Honolulu Police Department’s interactions with Sheldon on March
15 and 16, 2015, to which Defendant LEONG has never responded.
(84) On June 24, 2015, Christopher Happy, M.D., Chief
Medical Examiner (“Dr. Happy”) of the City and County of Honolulu
completed his autopsy report on Sheldon.
(85) Despite the privacy protections previously cited
to by Defendant KEALOHA, on or about June 30, 2015, Defendant
KEALOHA and the Honolulu Police Department issued two releases
and released two videos from the night of March 16, 2015, to
Hawaii media outlets depicting Sheldon’s last moments before he
was brutally electrocuted, attacked and killed by Defendants
CHUNG, CRITCHLOW, KARDASH, and/or other DOE DEFENDANTS.
(86) On or about July 1, 2015, Dr. Happy was
interviewed by media outlet KHON 2 and reported, consistent with
the autopsy report he completed, that Sheldon died from “multiple
metabolic and cardiac complications” and that he was “acutely
intoxicated.”
(87) In spite of Sheldon’s privacy rights and/or
Defendant CITY AND COUNTY OF HONOLULU and KEALOHA’s alleged

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“ongoing investigation,” the videos were immediately and broadly
reported on media outlets including Civil Beat, Hawaii News Now,
and K5 News Hawaii, and continue to be viewed and commented upon
by members of the public.

Dr. Happy’s comments were also widely

reported by KHON 2.
(88) On or about July 14, 2015, Defendant CITY AND
COUNTY OF HONOLULU, KEALOHA, and/or LEONG released a copy of the
Honolulu Medical Examiner’s autopsy performed on Sheldon without
notification of availability or prior release of the autopsy to
Plaintiffs.
(89) The contents of this autopsy report were again
immediately and broadly reported on by media outlets including
Civil Beat and continue to be viewed and commented upon by
members of the public.
(90) Plaintiffs finally received a formal copy of the
autopsy on July 15, 2015.
(91) Despite Plaintiffs’ repeated requests for other
documents, including all police reports and radio transmissions,
no other requested documents have ever been produced by
Defendants CITY AND COUNTY OF HONOLULU, LEONG, and/or KEALOHA to
Plaintiffs.
(92)

As a direct and proximate result of the manner in

which police press statements, videos, and Sheldon’s autopsy were
released to the public, in disregard of Plaintiffs’ requests and

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Sheldon’s privacy interests, Plaintiffs have suffered great
mental pain, anguish, suffering, severe emotional distress,
anxiety, embarrassment, humiliation, worry, and anger in amounts
to be proven at trial.
(93)

By preventing Plaintiffs from receiving all

requested information, covering up, and whitewashing the events
of March 16, 2015, with selective public release of information
and video recordings, Defendants CITY AND COUNTY OF HONOLULU,
KEALOHA, LEONG, and/or certain other DOE DEFENDANTS have impeded,
hindered, and obstructed the due course of justice and denied
Plaintiffs due process and equal protection of the laws thereby
proximately and directly causing injuries to Plaintiffs
complained of herein.
WHEREFORE, Plaintiffs pray for relief as follows:
(1)

For general damages in amounts to be proven at

(2)

For special damages in amounts to be proven at

(3)

For punitive damages against the individually

trial;

trial;

named Defendants;
(4)

For reimbursement of Plaintiffs’ costs and

expenses herein, including reasonable provision of his attorneys’
fees; and

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(5)

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For such further and additional relief as the

Court deems appropriate and just.
DATED:

Honolulu, Hawaii,

October 20, 2015

/s/ Eric A. Seitz
ERIC A. SEITZ
DELLA A. BELATTI
SARAH R. DEVINE
Attorneys for Plaintiffs

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