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Of Counsel:
KAWAMURA LAW OFFICE, LLLC.
Attorneys at Law

"fl'Q lJUL..
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ROBERT D. KAWAMURA 4537-0
350 Ward Avenue, Suite 106
Honolulu, Hawaii
96814
Telephone:
(808) 225-4200
Facsimile:
(808) 564-0850
Email:
AttorneysHawaii@aol.com
Website: AttorneysHawaii.com

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Attorneys for Plaintiffs
LIANNA MCCURDY and DANIEL VERDERAME

IN THE CIRCUIT COURT OF THE FIRST CIRCUIT
STATE OF HAWAI'I

. .

ClVll No.

LIANNA MCCURDY and DANIEL
VERDERAME,

19-1 -10 6 6- 0 7 DEO

(Motor Vehicle Tort)
COMPLAINT; DEMAND FOR JURY
TRIAL; SUMMONS

Plaintiffs,
vs.
ALINS SUMANG; SHELDON WATTS;
CITY AND COUNTY OF HONOLULU;
JOHN DOES 1-10; JANE DOES 1-10;
DOE CORPORATIONS 1-10; DOE
PARTNERSHIPS 1-10; DOE JOINT
VENTURERS 1-10; DOE LIMITED
LIABILITY ENTITIES 1-10; DOE
NON-PROFIT ENTITIES 1-10; DOE
GOVERNMENTAL ENTITIES 1-10; DOE
UNINCORPORATED ENTITIES 1-10;
and OTHER DOE ENTITIES 1-10,
Defendants.

COMPLAINT

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};{ ~(OJ [pJYf

 Plaintiffs LIANNA MCCURDY and DANIEL VERDERAME, by and
through their attorneys,
complaint

against

Kawamura Law Office,

Defendants

above-named,

LLLC.,
and

bring this

in

doing

so,

allege and aver as follows:
COUNT I - NEGLIGENCE
1.

Plaintiff

LIANNA

MCCURDY

is

and

was

at

all

relevant times herein a resident of the City & County Honolulu,
State of Hawaii {"Plaintiff MCCURDY").
2.

Plaintiff

DANIEL

VERDERAME

is

and

was

at

all

relevant times herein a resident of the City & County Honolulu,
State of Hawaii ("Plaintiff VERDERAME").
3.

Defendant ALINS SUMANG is and was at all relevant

times herein a resident of the City & County of Honolulu, State
of Hawaii ("Defendant SUMANG").
4.
relevant

Defendant

times

herein

SHELDON
a

resident

WATTS
of

is

the

and
City

was
and

at

all

County

of

Honolulu, Hawaii and at all relevant times herein was working in
the course and scope of his employment as a Police Officer with
the

Honolulu

Police

Department

("HPD"),

the

principal

law

enforcement agency within the City and County of Honolulu, State
of Hawaii.

("Officer WATTS").
5.

all

relevant

State

of

Defendant CITY & COUNTY OF HONOLULU is and was at
times

Hawaii

hereto

a

("Defendant

municipal
CITY") .

2

corporation within
At

all

relevant

the

times

 herein,

Defendant

officer

in

omissions

the
as

CITY

employed

Honolulu

alleged

Officer

Police

herein

WATTS

Department

caused

as

a

whose

and/or

police

acts

and

contributed

to

Plaintiffs' injuries and damages alleged herein and did so while
acting within the course and scope of his employment as a police
officer with Defendant CITY.
There

6.

between

Officer

existed

WATTS

and

relationship

master-servant

a

Defendant

CITY.

As

a

direct

and

proximate result of said officer's acts and omissions as alleged
herein,
forth

Plaintiffs
herein.

officer
liable

is

have

As

a

imputed

to

result

to

Plaintiffs

suffered

injuries

thereof,

Defendant
pursuant

CITY

to

the

and

damages

as

set

the

liability

of

and

Defendant

CITY

doctrine

of

said
is

Respondeat

Superior.
7.
DOE

Defendants JANE DOES 1-10, DOE CORPORATIONS 1-10,

PARTNERSHIPS

LIABILITY

1-10,

ENTITIES

GOVERNMENTAL

DOE

1-10,

ENTITIES

JOINT VENTURERS
DOE

1-10,

DOE

and OTHER DOE ENTITIES 1-10
Defendants")
liability

are

persons,

companies,

NON-PROFIT

1-10,

DOE

ENTITIES

UNINCORPORATED

LIMITED

1-10,

ENTITIES

(collectively referred to as

corporations,

business

entities,

partnerships,
non-profit

DOE
1-10,
"Doe

limited
entities,

and/or governmental entities who acted in a negligent, wrongful
or tortious manner which proximately caused or contributed to
injuries and damages sustained by Plaintiffs.

3

Plaintiffs have

 been unable to ascertain the names and identities of the abovenamed

Doe

Defendants

conducted

to

unidentified

from

Defendants

pursuant to Rule 17 (d)
and

Plaintiffs

capacities,

investigation

Accordingly,

date.
Doe

the

will

Plaintiffs

herein

under

that

has

been

have

sued

fictitious

the
names

of the Hawaii Rules of Civil Procedure,
substitute

the

acts and/or admissions

true

of the

names,
Doe

identities,

Defendants when

the same are ascertained.
8.

All

of

the

acts

and

omissions

complained

herein occurred within the City & County of Honolulu,

of

State of

Hawaii.
9.

Plaintiff MCCURDY has met all the requirements of

Hawaii No-Fault Law, including but not limited to H.R.S. Section
431-lOC-306 (b)
10.
of

Hawaii

(2)

&

(4), in bringing this suit.

Plaintiff VERDERAME has met all the requirements

No-Fault

Law,

Section 431-lOC-306 (b)
11.
their

damages

but

not

limited

to

H.R.S.

(4), in bringing this suit.

Plaintiffs
as

including

alleged

contend
in

that

this

jurisdictional requirements of this

the

amount

complaint

of

fall

Honorable Court,

each

within

of
the

exclusive

of interest, attorney's fees and costs.
12.

On

January

28,

2019,

Defendant

SUMANG had been

drinking and then began negligently operating a Ford F-150 Truck
("the Truck")

in the City and County of Honolulu losing control

4

 of the
Amana

Truck causing
and

Makaloa

it

to

collide

into

The

Honolulu

streets.

some parked cars
Police

on

Department

("HPDu) was notified that the Truck was fleeing the scene of one
of

the

collisions

on

Makaloa

looking for the Truck.
the

witness

Street

and

Officer

WATTS

began

Officer WATTS located a truck matching

description

on

nearby

Rycroft

Street

and

began

pursing it westbound on Rycroft Street and further pursued it as
it turned southbound onto Pensacola Street before he lost sight
of the Truck.

"Driving down Pensacola,

turn in

fran t

of us.

signs,"

Witness

Guy

I noticed a Ford truck

Didn't look like he stopped at any stop

Ogata

said.

"Shortly

after,

police that was following him. No sirens on was trying to pull him over."

there

was

a

I didn't think he

Officer WATTS began to look for

the truck and he again found it this time now westbound on Kona
Street.

According to witnesses Defendant SUMANG sped down Kona

Street followed by a police officer with lights on but no siren
sounding.
pi~ot

HPD Chief Susan Ballard said,

~ight

"We know he had his

on but as far as his flashing light,

under investigation.

that is still

Xhe siren was on at one point

chi~ing

on

and off that is all part of the investigation but generally when

you lose sight of a suspect vehicle you turn off your lights and
siren."

A witness

said,

"There

are

speed

bumps

that

were

totally ignored, i f I had put a number on it, it would be eighty
because they literally disappeared by the time I backed up and

5

 looked the other way."
sped westbound
then

sped

down

on

Ala

Kona

southbound

catch up to it.
Moana

Officer WATTS pursued the Truck as
Street

down

and

Piikoi

Street

The Truck made a

Boulevard

at

a

further
and

and

siren

difficult

high

to

give

maneuver

way

rate

the

to

through

the

weaving in and out of traffic.
Truck.

of

speed

to

with

truck,

Officer

traffic."

stopping

it

The

made

Truck

it
was

Officer WATTS lost sight of the

"The officer was unable

to keep up with the truck in the moving traffic."

Chief Ballard

"multiple officers then responded to help locate

said,

the truck and that's when
pedestrians

attempted

fire truck towing a

fire

According to HPD Chief Ballard,

further

it

reported "Everybody was

Officer WATTS

over
to

as

responding to another emergency with the lights

on.

and moving

he

it

right turn heading westbound

WATTS in pursuit but he got stuck behind a
boat which was

pursued

it

and

then

the driver plowed in to the crowd of

hit

another

vehicle

stopped

at

a

effort

to

stoplight."
13.
evade

At

Officer

all

WATTS

relevant
and

times

possibly

herein,
other

in

an

officers,

Defendant

SUMANG attempted to make a sudden right turn onto Kamakee Street
in

Kakaako

three

lanes

where

the

when

he

lost

control

and climbed the
Truck

violently

of

the

Truck

island in front
slammed

6

into

veering

across

of Kamakee

Street

eight

( 8)

pedestrians

 including Plaintiffs,

a light pole,

severing the pole and then

plowing into a pickup truck.
14.

HPD Lt.

James

Slayter

told the

Star Advertiser

that the truck had hit other cars several blocks away and then
sped across three lanes of traffic in an attempt to turn onto
Kamakee Street.
The accident occurred at approximately 6:20 p.m.

15.

on January 28, 2019.
16.
hosting

two

At

all

friends

relevant
Casimir

visiting from Pennsylvania,
the

street

when

the

times

herein,

Pokorny

and

his

Plaintiffs

were

girlfriend,

both

and they were all waiting to cross

Truck

plowed

Plaintiff VERDERAME'S best friend,

into

them.

Casimir

was

was just 26 years old and he

was tragically killed in the accident.
As

17.

negligence

of

a

direct

Defendant

SUMANG

suffered severe and permanent
psychiatric

and/or

and

proximate

as

alleged

injuries,

psychological

and

of

result
herein,

the

Plaintiffs

have incurred medical,

rehabilitative

expenses,

has suffered mental and emotional distress and have lost income
and earning capacity, and suffered other damages.
18.

As a

negligence

of

indi victuals

were

further and direct proximate result of the

Defendant
killed

SUMANG
and

at

suffered severe injuries.

7

as

least

alleged
three

herein,

other

three

indi victuals

 19.

At one of Defendant SUMANG' s

criminal hearings,

HPD Officer Brandon Ohta testified that the engine computer on
Sumang's truck recorded the vehicle's speed at 74-76 mph before
impact.

Officer Jason Tanaka testified that he

truck's

speed

pedestrians.

at

The

51

mph

speed

when

limit

it

for

hit

the

the

calculated the
light

subject

pole

portion

and

of Ala

Moana Boulevard is 35 mph.
20.

At

a

criminal

hearing

for

Defendant

SUMANG,

Investigating Police Officer Suaesi Tuimaunei testified that he
found

a

driving

bottle
and

that

of
he

vodka
was

in

the

truck

belligerent

and

Defendant
cursed

SUMANG
at

was

emergency

workers. Defendant SUMANG told emergency responders "Fuck you, I
don't

give

a

Fuck."

Court

documents

indicated

that Defendant

SUMANG smelled strongly of alcohol after the crash.
21.

In 2009, Defendant SUMANG was charged with

grand

larceny, aiding and abetting burglary, receiving stolen property
and

aiding

and

abetting

malicious

mischief

involving

the

burglary of the Imperial Bar in Palau.
22.

On December 23,

2015,

guilty of criminal property damage

Defendant SUMANG was found
in the City and County of

Honolulu.
23.
probation for

On March 30, 2017, Defendant SUMANG was placed on
a

2017

felony terroristic threatening conviction

in the City and County of Honolulu.

8

 24.
traffic

On January 28,

infractions

2019,

including

Defendant SUMANG had prior

driving

without

a

license

and

jaywalking in the City and County of Honolulu.
At

25.

all

relevant

times

herein,

Defendant

SUMANG

owed a duty to Plaintiffs to operate the Truck in a reasonably
safe and prudent manner observing all traffic laws and traffic
conditions.

Defendant

negligently

operated

negligence
influence

includes
of

SUMANG

his
but

alcohol,

breached

vehicle

is

not

speeding

as

duty

alleged

limited
and

this

to

when

herein,

driving

attempting

to

he

which

under

the

evade

the

officers' pursuit.
As

26.

negligence

of

discovered

in

permanent

Defendant

and

psychiatric,

direct

a

this

and

SUMANG

as

proximate
alleged

Plaintiffs

case,

disfiguring

psychological

injuries,
and

result
herein

each
have

and

suffered
incurred

rehabilitative

the

of
to

be

severe,
medical,

expenses,

have

suffered mental and emotional distress and have lost income and
earning

capacity,

and

suffered

other

damages,

entitling

Plaintiffs to a judgment against Defendant SUMANG in amounts to
be proven at trial.
COUNT II - NEGLIGENT PURSUIT
27.

Plaintiffs

reallege

and

incorporate

herein

by

reference all of the previous paragraphs of this complaint as if
fully set forth herein.

9

 28.
Department

At all relevant times herein, The Honolulu Police

had a

"MOTOR VEHICLE

PURSUITS" policy in place and

effect.
29.

According

to

said

policy,

its

purpose

is

to

"assist its officers in the safe performance of their duties and
to protect the public,
30.

.

According

II

to

Section

I.A.

of

said

policy,

a

"Motor Vehicle Pursuit" is "An effort by an officer operating a
motor vehicle to stop another motor vehicle when an occupant of
that vehicle is a suspected violator of the law and the driver
of that vehicle appears to be ignoring lawful commands to stop
or to be fleeing from
scene

of at

least

two

the police."
( 2)

Defendant SUMANG fled the

motor vehicle

collisions,

ran

stop

signs, sped away and failed to stop despite an officer following
him with his

lights on and siren chirping knowing that he had

just collided into parked vehicles.
31.

According to said Section II of said policy, some

"GENERAL CONSIDERATIONS" to consider in initiating a pursuit are
that:

A. Motor Vehicle pursuits may be hazardous because of
the .speeds and intricate maneuvers involved.
B. Therefore, in each decision to engage in a motor
vehicle pursuit, the need to apprehend the suspect
must be weighed against the need to avoid harm to
persons and property. In general, the greater the
risk of harm to the officer, the suspect, or the
public in the pursuit, the less justification there
is for the pursuit.

10

 32.

According

to

said

under "INITIATION OF PURSUIT",
be

used

to

command

initiated."

a

According

Section

III

of

said

policy,

"The blue light and siren shall

vehicle

to

to

Chief

HPD

stop

before

Ballard,

a

pursuit

is

Officer

WATTS'

said

policy,

pilot light was on but he only chirped his siren.
33.

According

to

Section

under "INITIATION OF PURSUIT",

III.

A.

of

"A pursuit may be initiated with

an authorized emergency vehicle if an officer directs a driver
to

stop

but

that

driver

officer by being evasive."

exhibits

intentions

of

eluding

the

Officer WATTS had his pilot light on

but only occasionally chirped his siren at Defendant SUMANG and
Defendant sped away down various streets.
34.
under

According

to

Section

"INITIATION OF PURSUIT",

motor vehicle pursuit,

III.

"When

an

the officer shall

flashing blue light and siren."

B.

of

said

policy,

officer initiates
continuously use

a

the

Defendant WATTS had his light

on but not flashing and only occasionally chirped his siren. HPD
Chief Ballard
far as his

stated, "We know he had his pil.ot l.ight on but as

flashing light,

that is

T.he siren was on at one point

still

chi~ing

under investigation.

on and off that is all

part of the investigation but generally when you lose sight of a
suspect you turn off the lights and siren."

11

 35.
"SUPERVISORY

According to Section IV. C. of said policy, under

becomes dangerous,
supervisor

to

"When

RESPONSIBILITIES",

the

pursuit

it shall be the responsibility of any field

terminate it."

down Kona Street,

continuing

Defendant

SUMANG was

speeding

Piikoi Street and on Ala Moana Boulevard and

was being pursued by Officer WATTS and possibly other officers
joined in after Officer WATTS
traffic.
was,

it

already

It
was

is

sight of him in the heavy

unclear if the pursuit was terminated;

terminated

speeding

lost

down

too

Ala

late
Moana

when

Defendant

Boulevard

into

if it

SUMANG
the

was

heavily

congested Kakaako area.
36.
said,

At all

relevant times herein,

HPD Chief Ballard

"The officer eventually observed the truck turn onto Ala

Moana Boulevard at a high rate of speed and weave in and out of
traffic.

The officer was unable to keep up with the truck in

moving traffic."

She said that multiple officers then responded

to help locate the truck and that's when the driver plowed into
the crowd of pedestrians waiting to cross the street and then
hit another vehicle stopped at a stoplight.
37.
pursuit

Officer WATTS and possibly other officers were in

of Defendant

SUMANG as

HPD Chief

Susan Ballard said,

"The siren was on at one point chirping on and off that is all
part of the investigation but generally when you lose sight of a
suspect vehicle you turn off your lights and siren."

12

 According to Section VI. A. of said policy, under

38.

"TERMINATION OF PURSUIT",

"A pursuit shall be terminated under

any one of the following conditions:
1. When the risk created by the pursuit is unreasonable
given the nature of the offense for which the
suspect is being pursued and the conditions under
which the pursuit must be conducted.

A.

An assessment of the risks created by the
pursuit should include: the speeds involved, the
volume of traffic on the road, the amount and
kind of pedestrian traffic in the area,
running a red light
or stop sign, time of day .

,

39.

The risk created by the pursuit was unreasonable

given that Defendant SUMANG had initially only been involved in
property damage collisions involving no injuries but then began
speeding down Kona Street, Piikoi Street and Ala Moana Boulevard
after Officer WATTS began pursuing him with his lights on and
chirping

siren

during

a

time

and

place

where

there

is

heavy

vehicular and pedestrian traffic in the area.
40.
lights

and

Defendant

At

no

time

continuous

SUMANG,

in

did

siren

Officer
when

contravention

WATTS

he
of

use

his

flashing

or

pursued

Motor

Vehicle

followed
the

HPD

Pursuits Policy.
41.
authorize

The

chirping

HPD Motor Vehicle
of

the

siren

as

Pursuits
an

Policy does

acceptable

method

not
of

pulling over a suspect or an acceptable protocol when pursuing a
suspect.

13

 42.

Officer WATTS should have attempted to pull over

Defendant SUMANG with his lights flashing and continuous siren
immediately

after

the

vehicle

collisions

instead

of

simply

following him up and down several streets with his lights simply
on and occasionally chirping his siren, causing Defendant SUMANG
to not pull over.

Officer WATTs pursuit in this fashion only

made

Defendant

SUMANG believe he

came

upon

opportunity

an

attempted,

by making

a

to

could

evade

sudden

turn

keep driving

the
at

pursuit,

a

high

rate

herein,

the

until

he

which

he

of

speed

resulting in him losing control of the Truck.
43.
including

At

all

relevant

Defendant WATTS,

times

owed a

duty to

officers

Plaintiffs

and the

other pedestrians to either pull over Defendant SUMANG and/or to
timely terminate the pursuit given the circumstances such as the
heavy vehicular and pedestrian traffic in the area at the time,
especially

in

light

of

the

fact

that

speeding dangerously down Kana Street,

Defendant
Piikoi

SUMANG

was

Street and then

down Ala Moana Boulevard despite being pursued by Officer WATTS.
44.

The officers breached this duty when they failed

to pull over Defendant SUMANG immediately following the vehicle
collisions
pursue

him

on Amana
down

and Makaloa

many

streets

streets
without

and

instead chose

flashing

lights

to
or

continuous siren pushing him into the heavily congested Kakaako
area causing him to attempt the sudden right turn onto Kamakee

14

 In his pursuit of

Street when he lost control of the Truck.
Defendant

SUMANG,

flashing

blue

Officer

lights

and

WATTS

should

continuous

have

siren

utilized

immediately

his
after

Defendant SUMANG fled the vehicle collisions to pull him over as
If Defendant

required by the HPD Motor Vehicle Pursuits Policy.

SUMANG did not then pull over as he was approaching the busy
Kakaako area, the pursuit should have been terminated.
45.
negligence

As

of

direct

a

Officer

and

proximate

and

possibly

WATTS

including officers yet to be identified,
to be discovered in this case,
permanent

and

psychiatric,

disfiguring

psychological

of

result
other

the

individuals

as alleged herein and

Plaintiffs each suffered severe,

injuries,
and

have

incurred

rehabilitative

medical,

expenses,

have

suffered mental and emotional distress and have lost income and
earning

capacity,

Plaintiffs

to

a

and

judgment

suffered
against

other
Officer

entitling

damages,
WATTS

and

Defendant

CITY in amounts to be proven at trial.
COUNT III - NEGLIGENT ENTRUSTMENT
46.

Plaintiffs

reallege

and

incorporate

herein

by

reference all of the previous paragraphs of this complaint as if
fully set forth herein.
4 7.
prior

traffic

At

the

time

infractions

of the

crash,

including

Defendant SUMANG had

driving

without

and jaywalking in the City and County of Honolulu.

15

a

license

He was also

 on

probation

conviction.

for
In

2017

a

2015,

He

felony

was

terroristic

also

found

threatening

guilty

of

criminal

property damage in the City and County of Honolulu and in 2009
he

had

been

burglary,

charged

with

receiving

grand

stolen

larceny,

property

and

aiding

and

abetting

aiding

and

abetting

malicious mischief involving the burglary of the Imperial Bar in
Palau.
48.
was

operating

At
the

all

relevant

times

Truck which was

herein,

Defendant

SUMANG

to

to be

registered

identified company on the island of Oahu.

a

yet

The company did not

report the Truck as stolen at the time of the accident.

owner

of

49.

At

all

the

Truck

relevant

knew

or

times

should

herein,

have

known

the

registered

that

Defendant

SUMANG was not a responsible or law abiding citizen and/or was a
reckless

individual

and

that

he

had

prior

infractions including driving without a license,
history,

that his careless,

motor

vehicle

and given this

reckless and irresponsible behavior

was reasonably foreseeable to continue and therefore said owner
should

have

taken

precautions

to

avoid

permitting

Defendant

SUMANG to have access to the Truck.
50.

At

all

relevant

times

herein,

the

registered

owner of the Truck owed a duty to not permit Defendant SUMANG to
operate the Truck.

16

 51.
owner

of

At

the

all

relevant

Truck

breached

times
its

herein,

duty

the

when

it

registered
negligently

entrusted the Truck to Defendant SUMANG.
As

52.

registered

owner's

Defendant

SUMANG

discovered

in

permanent

this

and

psychiatric,

as

and

direct

a

negligent
alleged
case,

entrustment
herein

and

of

in
each

injuries,

has

and

result

of

the

the

Truck

to

other

Plaintiffs

disfiguring

psychological

proximate

ways

suffered
incurred

rehabilitative

to

be

severe,
medical,

expenses,

has

suffered mental and emotional distress and have lost income and
earning

capacity,

Plaintiffs

to

a

suffered

and

judgment

against

other
the

damages,

entitling

registered owner of the

Truck in amounts to be proven at trial.
COUNT
IV
DISTRESS

NEGLIGENT/INTENTIONAL
53.

Plaintiffs

reallege

OF

INFLICTION
and

incorporate

EMOTIONAL
herein

by

reference all of the previous paragraphs of this complaint as if
fully set forth herein.
54.
were willful,
purposeful.

Defendants'
reckless,
These acts

actions

malicious,
were

described
outrageous,

above

and

below

deliberate,

committed with the

and

intention of

inflicting severe emotional distress upon Plaintiffs and/or were
done in reckless and/or negligent disregard of the probability
of causing Plaintiffs severe emotional distress.

17

 55.

As

Plaintiffs were
mental

and

anxiety,

a

direct

and proximate

caused to

emotional

result of said acts,

suffer serious,

distress,

strain,

entitling Plaintiffs to a

severe and grievous
anguish,

stress

and

judgment against Defendants

in amounts to be proven at trial.
COUNT V - PUNITIVE DAMAGES
56.

Plaintiffs

reallege

and

incorporate

herein

by

reference all of the previous paragraphs of this complaint as if
fully set forth herein.
57.
willful,

Defendant SUMANG's actions as alleged herein were

reckless,

malicious,

outrageous,

he told emergency responders,

and

in

At the scene of the

conscious disregard of the consequences.
accident,

deliberate,

"Fuck you,

I don't give

a Fuck."

58.
SUMANG's

As

willful,

a

direct

and

reckless,

proximate

malicious,

result

of

Defendant

outrageous,

deliberate

conduct in conscious disregard of the consequences,

Plaintiffs

are entitled to an award of punitive damages against Defendant
SUMANG to punish him and to

deter

this

type

of

reckless

and

outrageous conduct.
WHEREFORE, Plaintiffs pray for Judgment in their favor
and against Defendants, jointly and severally, as follows:
1.

Special damages as shall be proven at trial;

2.

General damages as shall be proven at trial;

18

 3.

Punitive damages against Defendant SUMANG as shall

be proven at trial;
4.

Attorney's fees and costs;

5.

Prejudgment and post-judgment interest; and

6.

Such other and further relief as the Court deems

just under the circumstances.
Dated: Honolulu, Hawaii,

l~

~,"'l-1\~

~~~~
ROBERTD:KAW
Attorneys for Plaintiffs
LIANNA MCCURDY and DANIEL
VERDERAME

19