Law Offices Of:
HARRISON & MATSUOKA

Electronically Filed
FIRST CIRCUIT
1PC151001338
31-OCT-2019
08:25 PM

WILLIAM A. HARRISON #2948
1001 Bishop Street, Suite 1180
Davies Pacific Center
Honolulu, Hawaii 96813
Telephone Number: 523-7041
Facsimile Number: 538-7579
E-Mail: wharrison@hamlaw.net
Attorney for Defendant
TIFFANY MASUNAGA

IN THE CIRCUIT COURT OF THE FIRST CIRCUIT
STATE OF HAWAII
STATE OF HAWAII
Plaintiff,
vs.
TIFFANY MASUNAGA,
Defendant.

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CR. NO. 15-1-01338
COUNT 10:
PROMOTING A DANGEROUS
DRUG IN THE FIRST DEGREE
(HRS§ 712-1241(1) (B))
COUNT 11:
PROMOTING A DANGEROUS
DRUG IN THE THIRD DEGREE
(HRS§ 712-1243)
COUNT 12 & 15:
PROMOTING A DANGEROUS
DRUG IN THE SECOND DEGREE
(HRS§ 712-1242(1)(A) ;(1) (B))
(Caption continued next page)

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COUNT 13:
PROMOTING A CONTROLLED
SUBSTANCE (HRS§ 712-1249.6)
COUNT 14:
PROMOTING DETRIMENTAL
DRUGS IN THE THIRD DEGREE
(HRS§ 712-1249)
COUNT 16:
PROMOTING HARMFUL DRUGS IN
THE THIRD DEGREE (HRS§ 7121246)
COUNT 17 & 18:
PROMOTING HARMFUL DRUGS IN
THE SECOND DEGREE (HRS§ 7121245(1) (A))
COUNT 19:
PROHIBITED ACTS RE DRUG
PARAPHERNALIA (HRS§ 329-43.5A)
MOTION TO DISMISS CASE AB
INITIO FOR PROSECUTORIAL
MISCONDUCT; DECLARATION
OF COUNSEL; EXHIBIT “A”;
NOTICE OF HEARING MOTION;
CERTIFICATE OF SERVICE
HEARING:
Date: January 14, 2020
Time: 2:30 p.m.
Judge: Hon. Catherine H. Remigio

 MOTION TO DISMISS CASE AB INITIO FOR PROSECUTORIAL
MISCONDUCT

COMES NOW, TIFFANY MASUNAGA, by and through her counsel
William A. Harrison and Harrison & Matsuoka, and hereby respectfully
moves this Honorable Court for an order dismissing the case, ab initio with
prejudice for prosecutorial misconduct.
This Motion and requested orders are brought pursuant to Rules 12,
16 (4) and 47 of the Hawai’i Rules of Penal Procedure, Rules 1.6, 3.3 (d), 3.8
and 4.2 of the Hawai’i Rules of Professional Conduct (“HRPC”),
Defendant’s rights to Due Process of Law and a fair trial, as guaranteed by
Article I, Sections 5 and 14 of the Hawaii State Constitution, and the 5th,
6th and 14th Amendments to the United States Constitution. This motion
is also supported by the Declaration of Counsel, the Memorandum in
Support of Motion, and any evidence, which may be presented at the
hearing on this matter.
DATED: Honolulu, Hawaii, October 30, 2019.
Law Offices Of:
HARRISON & MATSUOKA

/s/ William A. Harrison
WILLIAM A. HARRISON
Counsel for Defendant
TIFFANY MASUNAGA
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 IN THE CIRCUIT COURT OF THE FIRST CIRCUIT
STATE OF HAWAII
STATE OF HAWAII
Plaintiff,
vs.
TIFFANY MASUNAGA,
Defendant.

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CR. NO. 15-1-01338
COUNT 10:
PROMOTING A DANGEROUS
DRUG IN THE FIRST DEGREE
(HRS§ 712-1241(1) (B))
COUNT 11:
PROMOTING A DANGEROUS
DRUG IN THE THIRD DEGREE
(HRS§ 712-1243)
COUNT 12 & 15:
PROMOTING A DANGEROUS
DRUG IN THE SECOND DEGREE
(HRS§ 712-1242(1)(A) ;(1) (B))
COUNT 13:
PROMOTING A CONTROLLED
SUBSTANCE (HRS§ 712-1249.6)
COUNT 14:
PROMOTING DETRIMENTAL
DRUGS IN THE THIRD DEGREE
(HRS§ 712-1249)
COUNT 16:
PROMOTING HARMFUL DRUGS IN
THE THIRD DEGREE (HRS§ 7121246)
(Caption continued next page)

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COUNT 17 & 18:
PROMOTING HARMFUL DRUGS IN
THE SECOND DEGREE (HRS§ 7121245(1) (A))
COUNT 19:
PROHIBITED ACTS RE DRUG
PARAPHERNALIA (HRS§ 329-43.5A)
DECLARATION OF COUNSEL

DECLARATION OF COUNSEL
I, WILLIAM A. HARRISON, declare as follows:
1.

That Declarant is the attorney of record for TIFFANY

MASUNAGA herein;
2.

That Declarant has reviewed all the discovery provided him in

this case, spoken to Defendant and other witnesses and the facts contained
in the attached Memorandum are true and correct to the best of Declarant’s
knowledge and belief;
3.

That attached hereto as Exhibit “A” is a true and correct copy of

the Memorandum of Plea Agreement filed in the case of United States v.
Katherine Kealoha, Cr. No.: 19-00015-JMS-WRP; and
DECLARANT FURTHER ATTESTS, UNDER THE PENALTY OF
PERJURY THAT THE FOREGOING IS TRUE AND CORRECT TO THE

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 BEST OF HIS KNOWLEDGE AND BELIEF.
DATED: Honolulu, Hawai’i, October 30, 2019.
Law Offices of:
HARRISON & MATSUOKA

/s/ William A. Harrison
WILLIAM A. HARRISON

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 IN THE CIRCUIT COURT OF THE FIRST CIRCUIT
STATE OF HAWAII
STATE OF HAWAII

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Plaintiff,
vs.
TIFFANY MASUNAGA,
Defendant.

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CR. NO. 15-1-01338
COUNT 10:
PROMOTING A DANGEROUS
DRUG IN THE FIRST DEGREE
(HRS§ 712-1241(1) (B))
COUNT 11:
PROMOTING A DANGEROUS
DRUG IN THE THIRD DEGREE
(HRS§ 712-1243)
COUNT 12 & 15:
PROMOTING A DANGEROUS
DRUG IN THE SECOND DEGREE
(HRS§ 712-1242(1)(A) ;(1) (B))
COUNT 13:
PROMOTING A CONTROLLED
SUBSTANCE (HRS§ 712-1249.6)
COUNT 14:
PROMOTING DETRIMENTAL
DRUGS IN THE THIRD DEGREE
(HRS§ 712-1249)
COUNT 16:
PROMOTING HARMFUL DRUGS IN
THE THIRD DEGREE (HRS§ 7121246)
(Caption continued next page)

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COUNT 17 & 18:
PROMOTING HARMFUL DRUGS IN
THE SECOND DEGREE (HRS§ 7121245(1) (A))
COUNT 19:
PROHIBITED ACTS RE DRUG
PARAPHERNALIA (HRS§ 329-43.5A)
MEMORANDUM IN SUPPORT OF
MOTION

MEMORANDUM IN SUPPORT OF MOTION
I.

INTRODUCTION
Rudolph B. Puana (“Puana”), the brother of Katherine Kealoha, is a

board-certified anesthesiologist and pain doctor licensed to practice in the
State of Hawai’i. Beginning in or about July 2015, and continuing to
February 7, 2019, Puana was involved in a conspiracy to dispense and
distribute federally controlled substances which included Oxycodone,
Fentanyl and Xanax. As part of the conspiracy Puana would sell and barter
the controlled substances in exchange for cocaine, which was for his
personal use.
At some point Puana’s illegal activity was uncovered by a Honolulu
Police Department (“HPD”) Detective. When informed by the HPD
Detective of this fact, Katherine Kealoha assumed control of the
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 investigation, “which included herself Puana and others, to ensure they
were not prosecuted.” See Memorandum of Plea Agreement in Cr. No. 1900015 JMS-WRP, filed on October 22, 2019 – attached as Exhibit “A.”1
As part of the ongoing investigation, which included her brother, as
well as herself, Katherine Kealoha drafted and approved an affidavit in
support of a search warrant for the residence of defendant Tiffany
Masunaga. Katherine Kealoha concealed from the HPD Detectives working
on the drug conspiracy, the fact that Puana was involved in the drug
conspiracy. See Exhibit “A,” page 6.
Katherine Kealoha prevented HPD Detectives from questioning
Tiffany Masunaga about the source of the controlled substances, which
included 114 fentanyl transdermal patches2 which were recovered with
other drugs from Tiffany Masunaga’s residence.
During the prosecution of Tiffany Masunaga for drug crimes, which
surreptitiously involved Puana, DPA Kealoha “cultivated a close personal

This plea agreement was entered into by Katherine Kealoha and the
United States on October 22, 2019. Katherine Kealoha adopted the facts
contained in the plea agreement, under oath during her plea colloquy with
the court.
2 These 114 fentanyl patches were obtained from Puana.
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 relationship with [Tiffany]3- by, among other things, communicating with
[Tiffany] using an encrypted messaging app – to reduce the likelihood that
[Tiffany] would reveal Puana’s role in the drug conspiracy.” See Exhibit
“A,” at page 7. This was all while Tiffany was under the same indictment4
brought by Kealoha and was represented by counsel.5
Kealoha later offered Tiffany a plea agreement that “reduce[d] the
likelihood [that Tiffany] would reveal that Puana was the source of [the]
controlled substances seized and [that Puana] had participated in the
distribution of federally controlled substances.” See Exhibit “A,” at page 7.
Kealoha then orchestrated the sealing of the plea agreement, as well as the
plea hearing colloquy involving the terms of the plea. It took a Supreme
Court appeal to unseal that agreement and the plea hearing colloquy.
The plea agreement by the State controlled with whom Tiffany could
speak with. Therefore, effectively prohibited her from obtaining a
cooperation agreement with the federal government, thereby extinguishing
any possibly of obtaining federal immunity.

In the plea agreement Tiffany Masunaga is identified as “CC#4.”
4 An indictment which did not include Puana.
5 It was during this time that Tiffany was being represented by the same
counsel who was also representing Katherine Kealoha.
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 II.

ARGUMENT
A.

THE
PROSECUTORIAL
MISCONDUCT
IN
THIS
PARTICULAR MATTER IS SO EGREGIOUS THAT THE
ONLY REMEDY THAT WOULD PROTECT THE
INTEGRITY OF THE JUDICIAL PROCESS WOULD BE
DISMISSAL OF THIS CASE

In our system of justice, public prosecutors have a unique and
significant role:
Each decision [prosecutors] make [] has tremendous
impact on the lives of individuals involved, if not on the
entire community.
***
Prosecutors must strive diligently to raise the
ethical, technical, and professional standards of all
prosecutors throughout the nation. A single
unprofessional, corrupt, or unscrupulous prosecutor
can undo the fine work being done by the many
thousands of dedicated prosecutors throughout the
country.
The modern prosecutor cannot simply be the
defender of the status quo. He cannot be content to
simply perpetuate himself in office by withdrawing
from the frontline battle and practicing old routines.
He must be a respected voice in the community with
unquestioned integrity. From that operating base, he
must become a respected voice in the legislative
body of his jurisdiction. The prosecutor must truly
represent "the people" and conduct himself in a way
to make that obvious when he rises to state his
views in legislative halls.
11

 Hon. Evelle J. Younger, The Challenge of the Prosecutor's Office, in The
Prosecutor's Deskbook 3, 3-4 (Patrick F. Healy & Jason P. Manak, eds.,
1977).
Due to this role, public prosecutors owe a higher duty to the justice
system than other lawyers. As the United States, Supreme Court has
explained, the interest of a prosecutor:
is not that he shall win a case, but that justice be done. As such, he is
in a peculiar and very definite sense the servant of the law, the twofold aim of which is that guilt shall not escape or innocence suffer. He
may prosecute with earnestness and vigor—indeed, he should do so.
But, while he may strike hard blows, he is not at liberty to strike foul
ones.
Berger v. United States, 295 U.S. 78, 88 (1935); see also Collier v. State, 266 Ga
App. 345, 352, 596 S.E.2d 795, 802 (Ga. App. 2004) (“A prosecuting attorney
represents, not an ordinary party, but a sovereignty, whose obligation is to
govern impartially and whose interest in a particular case is not necessarily
to win, but to do justice.”); National Association of District Attorneys,
National Prosecution Standards § 1- 1.1 (3d ed. 2010) (“Nat’l Prosecution
Standards”) (“The prosecutor is an independent administrator of justice in
the criminal justice system.. The primary responsibility of a prosecutor is to
seek justice.”); American Bar Association, ABA Standards for Criminal
12

 Justice: Prosecution Function and Defense Function, Standard 3- 1,2(c) (3c1
ed. 1993) (“ABA Standards for Criminal Justice”) (“A prosecutor has the
responsibility of a minister of justice and not simply that of an advocate.
This responsibility carries with it specific obligations to see that the
defendant is accorded procedural justice ….”); Hawai’i Rules of
Professional Conduct, Rule 3.8 comment [1] (2014). Moreover,
This court has repeatedly noted that “[t]he prosecution has a duty to
seek justice, to exercise the highest good faith in the interest of the
public and to avoid even the appearance of unfair advantage over the
accused.” Quitog, 85 Hawai‘i at 136 n. 19, 938 P.2d at 567 n.
19 (quoting State v. Moriwaki, 71 Haw. 347, 354, 791 P.2d 392, 396
(1990)(citations and internal quotation marks omitted)); State v.
Pemberton, 71 Haw. 466, 476, 796 P.2d 80, 85 (1990). The American Bar
Association (ABA) Prosecution Function Standard 3–1.2(c) (3d
ed.1993) states that “[t]he duty of the prosecutor is to seek justice, not
merely to convict.”
State v. Rogan, 91 Hawai’i 405,412, 984 P.2d 1231, 1239 (1999); State v.
Moriwake, 65 Haw. 47, 56, 647 P.2d 705, 712 (1982).
Further, because of this role and the immense authority endowed to
the public prosecutor, she has a concomitant obligation as a public official
to seek to improve the justice system, an obligation well-established and oft

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 repeated in professional standards.6 As the National District Attorneys
Association admonishes its members:
A prosecutor. . . should put the rights and interests of society in
a paramount position in exercising prosecutorial discretion in
individual cases . . . [and] societal interests rather than
individual or group interests should also be paramount in a
prosecutor's efforts to seek reform of criminal laws.

Nat’l Prosecution Standards § L1-2. Therefore, it is understood, that
societal interests include a legal system where the prosecutor seeks justice
in an adversarial system and ensures that all those who come before a court
of law receive due process. Thus, prosecutors have a sworn duty to respect
the rights of criminal defendants.
A prosecutor must adhere to these high standards because of the dire
societal consequences that result from misconduct among public officials
who are charged with enforcing the law:

See, e.g., Model Rules of Prof’l Conduct, R 3.8 (2002) (the “Model Rules”);
Model Code of Prof’l Responsibility, EC 7-13 (1980) (the “Model Code”);
ABA Standards for Criminal Justice, Standards 3-1.2(c), 3-1.4(a)-(b); see also
Lee Adlerstein, Ethics, Federal Prosecutors, and Federal Courts: Some Recent
Problems, 6 Hofstra L Rev. 755, 755 n.3 (1978); Edwin H. Allier, Actions
Against Prosecutors who Suppress or Falsify Evidence, 47 Tex. L. Rev. 642, 642
(1969); Bennett L. Gershman, The Burger Court and Prosecutorial Misconduct,
21 Crim. L. Bull. 217 (1985); Walter W. Steele, Jr., Unethical Prosecutors and
Inadequate Discipline, 38 Sw. L.J. 965, 988 (1984).
6

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 Decency, security, and liberty alike demand that
government officials shall be subject to the same rules of
conduct that are commands to the citizen. In a government of
laws, existence of the government will be imperiled if it fails to
observe the law scrupulously. Our government is the potent,
the omnipresent teacher. For good or for ill, it teaches the whole
people by its example. Crime is contagious. If the government
becomes a law-breaker, it breeds contempt for the law; it invites
every man to become a law unto himself; it invites anarchy. To
declare that in the administration of the criminal law the end
justifies the means—to declare that the government may
commit crimes in order to secure the conviction of a private
citizen—would bring terrible retribution.
Olmstead v. United States, 277 U.S. 438, 485 (1928) (Brandeis, S., dissenting),
overruled in part by Katz v. United States, 389 U. S. 347 (1967) and Berger v.
New York, 388 U.S. 41 (1967).
Nothing will detract more from the proper administration of
the law than for the people to be impressed that the courts or
prosecuting officers are unfair in their treatment of those
charged with the law’s violation.
State v. Cox, 246 La. 748, 167 So.2d 352, 38 n.6 (1964) (quoting State v.
Nicholson, 7 S.W.2d 375 (Mo. App. 1928)).
The above law makes it clear that a prosecutor holds a special place
in our society that requires that she seek and do justice, not just merely
seek convictions.

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 From the inception of this case prosecutor Katherine Kealoha clearly
was involved in prosecutorial misconduct. She knew that her brother was a
co-conspirator in a drug ring and took every opportunity to cover that
matter up. Instead of acknowledging that her brother’s involvement in the
offense created an unresolvable conflict which required that she remove
herself from the case, she made a conscious decision to not only inject
herself into the case, but to intentionally cover up her brother’s culpability.
This she did to the detriment of Tiffany Masunaga.
Katherine Kealoha not only violated her sworn duty, she violated
other HRPC’s provisions, as well as National Prosecutorial standards. First,
as indicated she violated HRCP conflict rules as she had a personal stake in
the case and did nothing. Secondly, she violated national standards as a:
prosecutor should excuse himself or herself from any
investigation, prosecution, or other matter where personal
interests of the prosecutor would cause a fair-minded, objective
observer to conclude that the prosecutor’s neutrality, judgment,
or ability to administer the law in an objective manner may be
compromised.
National Association of District Attorneys, National Prosecution Standards
§ 1- 3.3 (Specific Conflicts) (3d ed. 2010).

16

 Thirdly, she communicated with Tiffany, a defendant who was
represented. HRCP Rule 4.2 states: “[i]n representing a client, a lawyer shall
not communicate about the subject of the representation with a person the
lawyer knows to be represented by another lawyer in the matter, unless the
lawyer has the consent of the other lawyer or is authorized to do so by law
or a court order.” Hawai’i Rules of Professional Conduct, Rule 4.2.
Moreover, by her involvement in the conspiracy and seeking to cover
up another’s involvement, Kealoha violated HRCP Rule 8.4 - “[i]t is
professional misconduct for a lawyer to: (a) attempt to violate the Rules of
Professional Conduct, knowingly assist or induce another to do so, or do so
through the acts of another; (b) commit a criminal act that reflects
adversely on the lawyer's honesty, trustworthiness, or fitness as a lawyer in
other respects; (c) engage in conduct involving dishonesty, fraud, deceit or
misrepresentation;….” Hawai’i Rules of Professional Conduct, Rule 8.4.
B.

AS A RESULT OF THE EGREGIOUS CONDUCT IN THIS CASE
THIS COURT HAS THE ABSOLUTE DISCRETION, AUTHORITY
AND INHERENT POWER TO DISMISS THIS MATTER WHICH
DEFENDANT SUBMITS IT SHOULD EXERCISE
In State v. Alvey, 67 Haw. 49, 57–58, 678 P.2d 5, 10 (1984), this court
noted that a judge's inherent power to dismiss an indictment is not
generally so broad as to dismiss an indictment with prejudice before
trial unless the State's misconduct represents a serious threat to the
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 integrity of the judicial process or there is a clear denial of due
process, a violation of some constitutional right, is an arbitrary action,
or is the result of some other governmental misconduct. . . We are
cognizant of the State's strong interest in prosecuting crime, but we
are equally cognizant that the State's duty is to pursue justice, not
convictions, and the prosecutor has a duty to act as a minister of
justice to pursue prosecutions by fair means. We must weigh the
State's interests against the defendants' rights to fundamental fairness
State v. Wong, 97 Hawai’i 512, 527, 40 P.3d 914, 929 (2002).
Furthermore:
In State v. Moriwake, 65 Haw. 47, 647 P.2d 705 (1982) this court held
that a trial court's power to administer justice may be properly
invoked to dismiss an indictment with prejudice. Our duty to
administer justice requires that we invoke that authority here to
mandate dismissal of these indictments with prejudice. As
the Moriwake court noted:
[W]e are cognizant of the deference to be accorded the prosecuting
attorney with regard to criminal proceedings, but such deference
is not without bounds. As stated elsewhere:
Society has a strong interest in punishing criminal conduct. But
society also has an interest in protecting the integrity of the
judicial process and in ensuring fairness to defendants in
judicial proceedings. Where those fundamental interests are
threatened, the “discretion” of the prosecutor must be subject
to the power and responsibility of the court. State v.
Braunsdorf, 98 Wis.2d 569, 297 N.W.2d 808, 817 (1980) (Day, J.,
dissenting).
State v. Wong, 97 Hawai’i 512, 527, 40 P.3d 914, 929 (2002), citing State v.
Moriwake, 65 Haw. 47, 56, 647 P.2d 705, 712 (1982).

18

 The prosecutorial misconduct in this matter: (1) represents a serious
threat to the integrity of the judicial process; (2) presents a clear denial of
due process; and (3) is a violation of Tiffany Masunaga’s constitutional
right of due process.

The misconduct therefore challenges the very

processes for which the State is mandated to uphold.
III.

CONCLUSION
Accordingly, based upon the authorities and arguments cited herein,

Defendant would respectfully request that this Honorable court grant the
above motion and dismiss this case ab initio with prejudice.
DATED: Honolulu, Hawai’i, October 30, 2019.
Law Offices of:
HARRISON & MATSUOKA

_/s/ William A. Harrison
WILLIAM A. HARRISON
Attorney for Defendant
TIFFANY MASUNAGA

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 IN THE CIRCUIT COURT OF THE FIRST CIRCUIT
STATE OF HAWAII
STATE OF HAWAII
Plaintiff,
vs.
TIFFANY MASUNAGA,
Defendant.

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CR. NO. 15-1-01338
COUNT 10:
PROMOTING A DANGEROUS
DRUG IN THE FIRST DEGREE
(HRS§ 712-1241(1) (B))
COUNT 11:
PROMOTING A DANGEROUS
DRUG IN THE THIRD DEGREE
(HRS§ 712-1243)
COUNT 12 & 15:
PROMOTING A DANGEROUS
DRUG IN THE SECOND DEGREE
(HRS§ 712-1242(1)(A) ;(1) (B))
COUNT 13:
PROMOTING A CONTROLLED
SUBSTANCE (HRS§ 712-1249.6)
COUNT 14:
PROMOTING DETRIMENTAL
DRUGS IN THE THIRD DEGREE
(HRS§ 712-1249)
COUNT 16:
PROMOTING HARMFUL DRUGS IN
THE THIRD DEGREE (HRS§ 7121246)
(Caption continued next page)

 )
)
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)
)
)
)

COUNT 17 & 18:
PROMOTING HARMFUL DRUGS IN
THE SECOND DEGREE (HRS§ 7121245(1) (A))
COUNT 19:
PROHIBITED ACTS RE DRUG
PARAPHERNALIA (HRS§ 329-43.5A)
NOTICE OF HEARING MOTION;
CERTIFICATE OF SERVICE

NOTICE OF HEARING OF MOTION
TO:

LANDON MURATA, ESQ.
Deputy Attorney General
845 Queen Street
Honolulu, Hawaii 96813
Attorney for State of Hawai’i
NOTICE IS HEREBY GIVEN that the above identified Motion, shall

come on for hearing before The Honorable Catherine H. Remigio, Judge of
the above-entitled Court, in her courtroom at 777 Punchbowl Street,
Honolulu, Hawaii, 96813 at 2:30 p.m., on January 14, 2020, or as soon
thereafter as counsel can be heard.
DATED: Honolulu, Hawaii, October 30, 2019.
Law Offices of:
HARRISON & MATSUOKA

/s/ William A. Harrison
WILLIAM A. HARRISON
Attorney for Defendant
TIFFANY MASUNAGA
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 CERTIFICATE OF SERVICE
The undersigned hereby certifies that a copy of the foregoing Motion
will be served on the above-identified parties at their respective addresses
by means of Email and/or hand delivery on the date of filing or as soon
thereafter as practicable.
DATED: Honolulu, Hawaii, October 30, 2019.
Law Offices Of:
HARRISON & MATSUOKA

__/s/ William A. Harrison
by WILLIAM A. HARRISON
Attorney for Defendant
TIFFANY MASUNAGA

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