OTA & HARA

A LIMITED LIABILITY LAW COMPANY

Electronically Filed
LEIGHTON M. HARA 7826-0 FIRST CIRCUIT
[email protected] 1CCV-24-0001054
KALLISTA N. HIRAOKA 11328-0 02-AUG-2024
[email protected] 08:56 AM
Pacific Guardian Center, Mauka Tower Dkt. 1 CMPS
737 Bishop Street, Suite 2860
Honolulu, Hawaii 96813
Tel. No. (808) 532-1728
Fax No. (808) 532-1729

Attorneys for Plaintiff

Arnold Laanui, Jr.

IN THE CIRCUIT COURT OF THE FIRST CIRCUIT

STATE OF HAWAII

ARNOLD LAANUI, JR., ) CIVIL NO. _____________________

) (Other Civil Action)
Plaintiff, )
) COMPLAINT; DEMAND FOR JURY
vs. ) TRIAL; SUMMONS
)
THE CONGREGATION OF CHRISTIAN )
BROTHERS OF HAWAII, INC., a Hawaii )
Corporation dba DAMIEN MEMORIAL )
SCHOOL; JOHN DOES 1-10; JANE DOES )
1-10; DOE ENTITIES 1-10, )
)
Defendants. )
)

COMPLAINT

Plaintiff ARNOLD LAANUI, JR. by and through his attorneys, hereby complains

against Defendants THE CONGREGATION OF CHRISTIAN BROTHERS OF HAWAII, INC.,

a Hawaii Corporation dba DAMIEN MEMORIAL SCHOOL; JOHN DOES 1-10; JANE DOES

1-10; and DOE ENTITIES 1-10 (collectively “Defendants”) as follows:

 JURISIDICTION AND VENUE

1. This Court has subject matter jurisdiction over the claims set forth in this

Complaint pursuant to Hawaii Revised Statutes (“HRS”) § 603-21.5 and has personal

jurisdiction over Defendants pursuant to HRS § 634-35. Venue is appropriate in the Circuit

Court of the First Circuit, State of Hawaii pursuant HRS § 603-36.

PARTIES

2. Plaintiff ARNOLD LAANUI, JR. (“Dr. Laanui” or “Plaintiff”) is a

resident of Honolulu, Hawaii and was employed by Defendant THE CONGREGATION OF

CHRISTIAN BROTHERS OF HAWAII, INC., a Hawaii Corporation dba DAMIEN

MEMORIAL SCHOOL (“Damien”), at all times relevant herein.

3. Defendant Damien is a domestic nonprofit corporation registered to do

business in the State of Hawaii, and its primary purpose is as private, Roman Catholic school for

children in grades 6 through 12. At all times relevant herein, Damien has continuously done

business at its principal place of business in the City and County of Honolulu, State of Hawaii.

4. JOHN DOES 1-10; JANE DOES 1-10; and DOE ENTITIES 1-10 are

individuals, corporations, partnerships, limited partnerships, joint ventures, and/or other entities

named hereunder fictitious names for the reason that their true identities are presently unknown

to Dr. Laanui, except that they are persons and/or entities who are subsidiaries, agents,

associates, masters, servants, employees and/or who were in some manner presently unknown to

Dr. Laanui engaged in activities alleged in the Complaint filed herein; and/or who are in some

manner responsible for the damages to Dr. Laanui; and/or who conducted some activity in a

negligent and/or intentional manner, which negligent and/or intentional conduct was a proximate

cause of the injuries or damages to Dr. Laanui; and/or who are in some manner related to

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Damien; and Dr. Laanui prays leave to insert herein their true names and capacities, activities,

and/or responsibilities when the same are ascertained. Dr. Laanui has conducted research

through third parties in order to identify the persons and/or entities liable for the damages to

Dr. Laanui complained of herein. Dr. Laanui has conducted independent research through a

third party to ascertain the corporate identities of Defendants. Dr. Laanui at this time is unable to

identify the names and identities of the persons and/or entities until Dr. Laanui proceeds with

discovery.

SUMMARY OF THE ACTION

5. Dr. Laanui beings this action for equitable relief and monetary damages as

a result of the following acts and occurrences:

a. Retaliation against Dr. Laanui for reporting suspected improper

and unlawful conduct by Defendant Damien, including group sex involving

minors on Damien’s campus; Damien’s failure to pay taxes; Damien’s violations

of Title IX; and reports of fraud and embezzlement by Damien football coaches in

violation of HRS § 378-62;

b. Retaliation against Dr. Laanui in violation of Hawaii State law and

public policy; and

c. Breach of Dr. Laanui’s employment contract with Damien.

6. The retaliation was known and tolerated by Damien and its Board of

Directors (“Board”), Congregation of Christian Brothers (“Christian Brothers”), agents, and

supervisory and managerial employees.

7. Damien’s conduct was willful, wanton, intentional, and outrageous.

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 STATEMENT OF FACTS

Damien’s History of Sexual Abuse

8. Defendant Damien was established in 1962 as an all-boys, Catholic,

college preparatory institution based on the tradition of the Irish Chrisian Brothers and their

corporate entity, The Congregation of Christian Brothers of Hawaii, Inc., with its principal place

of business at 1401 Houghtailing Street, Honolulu, Hawaii 96817. Damien became

coeducational beginning from the 2012-2013 school year.

9. Defendant Damien’s history is marred by rampant sexual abuse by clergy,

including but not limited to the Rev. Gerald Funcheon (“Rev. Funcheon”), a priest who taught at

Damien in the early 1980’s and has admitted in a deposition that he had sexual contact with a

dozen or as many as 18 youth while he was a priest. Rev. Funcheon admitted to touching a

Hawaii youth in a sexual manner while the two were showering together in a cabin and took

nude photographs of boys. As a result of Rev. Funcheon’s sexual misconduct, various former

Damien students filed lawsuits against Damien.

10. Defendant Damien was also sued by two former students who were

abused by Brother Robert Brouillette (“Brother Brouillette”) on the Damien campus in 1984 and

1986. Damien covered up tortuous sexual abuse by Brother Brouillette. As a result of Brother

Brouillette’s sexual misconduct, various former Damien students filed lawsuits against Damien.

Damien is aware of numerous cases of sexual abuse against former clergy/teachers and have

settled the matters through monetary payments.

11. In 2013, the first year Damien became coeducational, a male student who

was on the wrestling team sexually abused a female student on the Damien campus which

prompted the female student to sue Damien. Damien resolved this lawsuit.

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 12. Based on these lawsuits, other similar lawsuits 1, and the law, Damien has

a duty to guard against sexual abuse on campus and should have a heightened awareness for

identifying and preventing all forms of sexual abuse.

13. On January 3, 2019, Damien fired its President Wes Reber Porter

(“Mr. Porter”), along with two volunteer leaders, after they resisted a request from the Christian

Brothers to set aside over a million dollars in potential costs to settle sex assault lawsuits

stemming from Damien’s extensive history of sexual abuse.

14. On January 8, 2019, Damien replaced Mr. Porter, who had only served as

Damien’s president for approximately 30 months, with Brother Brian M. Walsh (“Brother

Walsh”) from the Christian Brothers.

15. In 2016, Brother Walsh signed a $1.9 million settlement with 21 student

victims who were abused at Bergen Catholic High School between 1963 and 1978, when Brother

Walsh was president.

Damien hires Dr. Laanui as President and CEO

16. In June 2020, Damien announced that Brother Walsh would not return as

president.

17. Following Brother Walsh’s dismissal, Damien operated without a

president until Dr. Kyle Ataby assumed the role of interim president at the end of June 2020.

18. On July 1, 2022, Damien and Dr. Laanui entered into an employment

agreement that extended until June 30, 2025, where Dr. Laanui agreed to serve as the President

and Chief Executive Officer (“CEO”) of Damien.

1
Other clergy who were known to have sexually abused minors at Damien include: Brother Lawrence Robert
Christensen; Brother Bruce J. Cullerton; Brother Thomas Duffin; Brother Thomas Cuthbert Ford; Brother John Paul
Medvit; Father Lawrence M. Spellen; and Brother Douglas Zlatis.

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 19. Dr. Laanui is a former educator (State of Hawaii Department of Education

District Education Specialist), Federal Bureau of Investigations (“FBI”) Special Agent, and a

1986 alumnus of Damien.

20. As an FBI agent, Dr. Laanui solved crimes and served as a member of the

FBI SWAT, receiving Hawaii’s Top Cop award and teaching as an FBI advanced instructor and

adjunct faculty member of the FBI Academy.

Dr. Laanui Reports Suspected Violations of Law

21. When Dr. Laanui became President and CEO, Damien was in poor fiscal

health and Dr. Laanui made tough decisions to improve Damien’s financial wellbeing.

22. Auditors described the system Dr. Laanui inherited as having “significant

material weaknesses” regarding Damien’s internal controls. Prior to Dr. Laanui’s arrival,

Damien’s last audit occurred in the school year 2019-2020, where the auditors observed that

Damien was rife with significant material weaknesses and that Damien was unwilling to fully

cooperate with the auditors.

23. Dr. Laanui also obtained a $2.1 million grant for Damien, which is the

largest grant in Damien’s history.

24. During his tenure, Dr. Laanui witnessed several suspected violations of

law which he reported to the Damien Board and the Christian Brothers, including but not limited

to: group sex on campus involving a minor; fraud; violations of Title IX and Interscholastic

League of Honolulu (“ILH”) recruiting rules; and embezzlement.

Group Sex on Campus Involving a Minor

25. In February 2023, Shawn Sueoka (“Mr. Sueoka”), Damien Athletic

Director, informed Dr. Laanui that Anthony Tuitele (“Coach Tuitele”), the head football coach,

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attempted to conceal an on-campus sex incident involving minor students that occurred during a

Damien sanctioned football sleepover in October 2022. Five students (four football team

members and a female equipment manager) engaged in group sex during the sleepover on

Damien’s campus.

26. Dr. Laanui informed the Board that the conduct may be criminal because

the girl involved was a minor and incapable of consent. Dr. Laanui reported that Damien could

be in violation of the law because the lax supervision by Damien staff allowed for the sexual

activity involving minors to occur.

27. Dr. Laanui reminded the Board that this situation was like the recent

sexual assault claims that were brought against St. Louis High School involving a minor female

and two former football players. Dr. Laanui explained that the female student may have

allegedly consented, but because she is a minor, she is not capable of consent and could change

her mind and file a lawsuit when she turned 18.

28. Dr. Laanui endorsed Principal Kyle Atabay’s recommendation to dismiss

the five students for violating Damien’s policy prohibiting sexual relations on campus.

29. Dr. Laanui also supported Principal Kyle Atabay’s recommendation to

discipline Coach Tuitele for failing to supervise the students and for covering up the event.

30. As a result of reporting suspected violations of law involving on-campus

group sex involving minors, Dr. Laanui received backlash from certain members of the

community, the football coaching staff, and Board members.

Fraud and Damien Alumni Association Misconduct

31. In February 2023, the Damien Alumni Association (“DAA”) hosted a

Food & Wine Festival fundraiser on Damien’s campus.

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 32. Dr. Laanui learned that despite being marketed as a fundraiser for Damien,

the proceeds or donations were not shared with Damien. Monies from the DAA golf tournament

and donations received by members of the DAA at a separate Damien sponsored golf tournament

were also not shared with Damien.

33. In March 2023, during an audit and accreditation review, auditor Carleton

Williams of CW Associates, informed Dr. Laanui that the DAA was not properly registered with

the IRS or State of Hawaii as a non-profit organization; that monies from the fundraisers held by

the DAA were not flowing directly to Damien; that there was possible criminal liability for the

DAA’s failure to pay taxes; and that Damien may be liable for sanctioning the DAA’s

misrepresentations, including tax issues related to improper DAA scholarships earmarked for

Damien football players. Dr. Laanui was also informed by the accreditors that DAA was

“rogue” and should be reconstituted “under one roof.”

34. In March 2023, Floyd Baptist (“Mr. Baptist”), a Board Member,

threatened to terminate Dr. Laanui’s employment if Dr. Laanui refused to sign a contract

allowing the DAA to run the school’s lu’au fundraiser. Dr. Laanui advised Mr. Baptist that

Damien would run its own lu’au fundraiser, independent of the DAA.

35. In April 2023, Dr. Laanui reported the violations of tax laws and the

DAA’s improprieties to the Congregational Sponsor Council and Betsey Gunderson

(“Ms. Gunderson”), President of the Damien Board.

Dr. Laanui Reports Violations of Title IX, ILH Rules, and Damien Policies

36. In April 2023, Dr. Laanui discovered that Coach Tuitele attempted to

improperly divert monetary donations to Damien by funneling scholarships from the DAA to his

star football players.

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 37. Parents informed the Damien Business Office that they were not paying

their children’s tuition, because they were waiting to pay with money provided by Coach Tuitele

through the football program. An audit revealed that the DAA made tuition payments to football

players.

38. On April 26, 2023, Dr. Laanui complained to the Board and the Damien

Sponsor Council that Damien had an issue with a recruiting scheme perpetuated by Coach

Tuitele where prominent football players were allowed to play football at Damien in a pay-for-

play scheme that violated tax laws, Title IX of the Education Amendments of 1972 which

prohibit discrimination based on sex in education programs and activities that receive federal

financial assistance, ILH recruitment rules prohibiting pay-to-play activities, and Damien

policies regarding financial aid.

Dr. Laanui Reports Online Identity Theft

39. In May 2023, Ms. Gunderson sanctioned an informal survey of

Dr. Laanui, with his permission, that would be used as a voluntary, formative assessment. The

survey was designed to support Dr. Laanui’s improvement goals for Damien for his second year.

40. Contrary to the official informal survey Ms. Gunderson approved, a false

Google survey was circulated to the Damien community, which misrepresented that it was an

authentic Board action. This false survey sullied the reputation of Damien, and more

specifically, Dr. Laanui.

41. Ron Malalis, a board member who is also President of the DAA,

submitted the results of the survey to Ms. Gunderson.

42. Dr. Laanui reported this false Google survey to Ms. Gunderson and that

such an act was illegal. Ms. Gunderson agreed.

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 43. Dr. Laanui reported this misconduct to the Sponsor Council members

Brother Lawrence T. Murphy (“Brother Murphy”), Brother Michael Segvich, Brother Edward

Brink, and Deacon Michael Weaver and stressed that it was criminal behavior. Dr. Laanui

reiterated the following suspected illegal activities: (a) ongoing Title IX violations regarding

improper “scholarships” for football players; (b) violation of ILH policy for using pay-to-play

scholarships for football players; (c) criminal culpability by the DAA and Damien, where the

DAA falsely claimed to be tax exempt and failed to pay taxes; and (d) misrepresentation and

misappropriation of funds through fundraising by the DAA (fraud).

44. Before Dr. Laanui could expound on his complaints of illegal activity, the

Sponsor Council members ended the meeting and advised Dr. Laanui that they were

uncomfortable with these issues which should be resolved “with the Board.”

Dr. Laanui Reports Fraud by Coach Tuitele and Ronald Dalmacio

45. In December 2023, Dr. Laanui discovered that Coach Tuitele and the

intermediate football coach, Ronald Dalmacio (“Coach Dalmacio”), engaged in significant

financial fraud by giving themselves a “bonus” for winning the 2023 football season.

46. Coaches Tuitele and Dalmacio submitted a $6,000 invoice for a football

banquet, but there was no intent by either Coach to have the banquet; instead, they were going to

pocket the money. Mr. Sueoka and Coach Tuitele admitted to Dr. Laanui that the monies for the

banquet were intended to go to the Coaches as a bonus.

47. Dr. Laanui reported this misconduct and the results of his investigation to

the Board’s Executive Committee and members of the Board’s Executive Committee agreed

with his decision to terminate the Coaches’ employment.

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 48. On Wednesday, December 13, 2023, Dr. Laanui, with approval from the

Board’s Executive Committee, approved Coaches Tuitele and Dalmacio’s termination of

employment with Damien.

49. Dr. Laanui received a significant amount of public backlash for

terminating the coaches, which resulted in numerous protests by Damien Alumni, community

members, and supporters of the football program.

50. On January 23, 2024, Brother Lawrence T. Murphy and Brother Michael

Segvich, members of the Christian Brothers serving as Chair of the Congregation and Sponsor

Council, met with Dr. Laanui.

51. During this meeting, Dr. Laanui complained about waste, fraud,

embezzlement, and abuse occurring at Damien. He also reiterated that the Coaches had to be

removed for their role in submitting a fraudulent invoice.

52. Instead of supporting Dr. Laanui, Brother Tom Murphy and Brother Ed

Segvich suggested that he take some time off and consider if he wishes to continue at Damien.

Dr. Laanui reaffirmed his commitment to Damien.

53. On January 26, 2024, Damien hired ALTRES to conduct a review of the

investigation into Coaches Tuitele and Dalmacio’s embezzlement.

54. ALTRES concluded that the decision to remove the Coaches was prudent

and in the best in interest of Damien.

55. ALTRES made the following observation:

Given the high profile of the coaches within the school and their
visibility in the broader community, along with the timing of the
terminations, the school was faced with a very difficult decision:
Terminate the coaches based on behavior/action that were in
direct conflict with the school’s policies, philosophy, and

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 Catholic moral standards, or sweep it under the rug and allow
a culture of dishonesty and lack of remorse/accountability to
continue.

56. Following the termination of the Coaches, Damien retained the services of

the Office of Educational Services (“OES”) to conduct a professional review of Dr. Laanui on

February 5 and 6, 2024.

57. On February 6, 2024, the OES concluded its review and met with

Dr. Laanui and Board Chair Betsey Gunderson. OES noted the controversy regarding the

football program and commended Dr. Laanui in certain areas (implementing financial best

practices, improving Damien’s financial well-being and greatly improving Damien’s much

neglected grounds and facilities), and offered suggestions for growth.

58. The OES report concluded with the following:

We hope the recommendations contained in this report will be

implemented collaboratively and used to mend fractured
relationships and overall feeling of suspicion and mistrust. We
pray for blessings on Dr. Laanui, the Sponsor Council, the Board
of Directors and the entire school community as Damien moves
into the future.

59. The OES review team unanimously stated that these relationships are

repairable. Notably, the OES report does not include any recommendation for termination of

Dr. Laanui’s employment or any other type of discipline.

Dr. Laanui is Terminated for Reporting Violations of Law

60. On February 9, 2024, following Dr. Laanui’s numerous complaints about

suspected violations of law and policy, Brother Murphy and Board Vice Chair Wally Marciel

informed Dr. Laanui that he would be terminated effective immediately.

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 61. Brother Murphy said he would advise the community that Dr. Laanui had

resigned and that Damien pursued another direction and change of leadership. Brother Murphy

told Dr. Laanui that his separation was premised on a survey given to the parents and teachers.

62. Brother Murphy did not raise any “for cause” reasons for Dr. Laanui’s

termination from employment.

63. Brother Murphy also presented Dr. Laanui with a Severance Agreement,

which among other things, provided for the continuance of Dr. Laanui’s salary and benefits until

June 30, 2025, consistent with his employment contract.

64. The Severance Agreement did not mention any “for cause” reasons for

Dr. Laanui’s termination from employment.

65. On Friday, February 16, 2024, at 7:27 pm Principal Pua Higa (“Dr. Higa”)

informed Dr. Laanui that she was investigating the Coaches’ misconduct. Dr. Higa informed

Dr. Laanui that she wanted to interview him by Wednesday, February 21, 2024.

66. Dr. Laanui thought this was strange because ALTRES and the Board

Executive Committee approved the decision to terminate Coach Tuitele and Coach Dalmacio.

67. On Saturday, February 17, 2024, at 1:13pm, Dr. Higa advised that she

wanted to conclude her investigation by Tuesday, February, 20, 2024. Dr. Higa further advised

that “If I do not hear back from you by tomorrow (Sunday) at 4pm, I will assume that you will

not be participating in the interview process or providing any other documents.”

68. At the time of these emails, Dr. Laanui was at the hospital supporting his

father-in-law who was undergoing an amputation and February 19, 2024 was President’s Day.

69. On February 20, 2024, Dr. Laanui informed Ms. Higa that he would get

back to her on her request to interview him.

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 70. Ms. Higa never spoke with Dr. Laanui again.

71. On February 24, 2024, there was a press release noting that Damien

reinstated Coach Tuitele and Coach Dalmacio to their coaching positions.

72. On March 7, 2024, almost a month after Dr. Laanui was wrongfully

terminated in retaliation for reporting suspected violations of law and policy, Brother Murphy

sent a letter to Dr. Laanui informing him that he was terminated “for cause” and that he would

not be entitled to the severance promised to him and memorialized in his employment contract.

CAUSES OF ACTION

FIRST CAUSE OF ACTION: VIOLATION OF THE HAWAII

WHISTLEBLOWER PROTECTION ACT

73. Dr. Laanui realleges and incorporates by reference the allegations of each

of the preceding paragraphs.

74. Defendant discharged, threatened, or otherwise discriminated against

Dr. Laanui because he reported to his employer, violations or suspected violations of a law or

rule adopted pursuant to laws of the State of Hawaii, the City and County of Honolulu, and/or

the United States.

75. Defendant violated HRS § 378-61, et seq. by threatening and/or otherwise

discriminating against Dr. Laanui regarding the terms, conditions, and privileges of his

employment because of his reports of unlawful conduct.

76. Defendant’s conduct also runs afoul of its core values espousing the

message of the Gospel of Jesus Christ, and, specifically, demonstrates a lack of integrity,

excellence, and accountability.

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 77. Any excuses proffered by Defendant for disparate, discriminatory, and/or

retaliatory treatment of Dr. Laanui are pretextual attempts to justify Defendant’s adverse

employment action against Dr. Laanui.

78. As a direct and proximate result of Defendant’s misconduct, Dr. Laanui

has suffered damages for injury or loss, including wage loss, general damages, and attorneys’

fees. Dr. Laanui is entitled to the statutory remedies under the Hawaii Whistleblower Protection

Act.

SECOND CAUSE OF ACTION: WRONGFUL AND RETALIATORY

TERMINATION IN VIOLATION OF PUBLIC POLICY

79. Dr. Laanui realleges and incorporates by reference the allegations of each

of the preceding paragraphs.

80. Dr. Laanui is protected from adverse employment action in violation of

public policy as set forth in Parnar v. Americana Hotels, Inc., 65 Haw. 370, 652 P.2d 625

(1982).

81. Dr. Laanui reasonably believed that Defendant, through the actions of its

employees and affiliates, like the DAA, was in violation of the law when he complained to the

Damien Board and Sponsor Council about the misconduct.

82. Defendant, its employees and agents, wrongfully terminated Dr. Laanui

from his employment because he reported violations to his employer and his supervisors who

were agents and/or employees of Defendant.

83. As a direct and proximate result of Defendant’s wrongful termination of

Dr. Laanui in violation of public policy, Dr. Laanui suffered indignities, anguish, pain, emotional

distress, fear, humiliation, damage to his reputation and career, and other damages in amounts to

be proven at trial.

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 84. In performing all the acts and omissions described above, Defendant,

individually or through its employees and/or agents, acted intentionally, willfully, wantonly,

oppressively, or with gross negligence. Defendant is therefore liable to Dr. Laanui for punitive

damages in amounts to be determined at trial.

85. As a further result of Defendant’s actions, Dr. Laanui has necessarily

retained attorneys to prosecute this action. Dr. Laanui is therefore entitled to an award of

reasonable attorneys’ fees and litigation expenses incurred in bringing this lawsuit.

THIRD CAUSE OF ACTION: BREACH OF CONTRACT

86. Dr. Laanui repeats and realleges the allegations contained in the preceding

paragraphs as through fully set forth herein.

87. Dr. Laanui had a contract with Damien, which required Damien to

compensate Dr. Laanui with an annual salary of $150,000 and benefits.

88. The contract requires Damien to pay Dr. Laanui the equivalent of the

remaining months of his annual salary otherwise payable under the contract from the date of

termination through June 30, 2025.

89. Dr. Laanui received his last paycheck on February 22, 2024, two weeks

after his termination date of February 9, 2024.

90. Damien breached the contract by failing to pay Dr. Laanui the

compensation he is owed.

91. As a result of Damien’s breach, Dr. Laanui is entitled to damages in an

amount to be determined at trial.

92. Some or all of the acts and omissions set forth above were done by

individuals and entities who were acting within the course and scope of their employment and/or

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actual and/or apparent agency relationship with Damien, and Damien is vicariously liable for the

acts of its employees/agents under the doctrine of respondeat superior.

WHEREFORE, Plaintiff prays for Judgment against the Defendants jointly and

severally, as follows:

1. For special damages in amounts to be proven at trial.

2. For general damages in amounts to be proven at trial.

3. For punitive damages in amounts to be proven at trial.

4. For payment of Plaintiff’s costs and attorney’s fees.

5. For further legal relief as provided under HRS Chapter 378.

6. For such other relief as the Court deems appropriate.

DATED: Honolulu, Hawaii, August 2, 2024.

/s/ LEIGHTON M. HARA

LEIGHTON M. HARA
KALLISTA N. HIRAOKA

Attorneys for Plaintiff

ARNOLD LAANUI, JR.

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 IN THE CIRCUIT COURT OF THE FIRST CIRCUIT

STATE OF HAWAII

ARNOLD LAANUI, JR., ) CIVIL NO. ____________________

) (Other Civil Action)
Plaintiff, )
) DEMAND FOR JURY TRIAL
vs. )
)
THE CONGREGATION OF CHRISTIAN )
BROTHERS OF HAWAII, INC., a Hawaii )
Corporation dba DAMIEN MEMORIAL )
SCHOOL; JOHN DOES 1-10; JANE DOES )
1-10; DOE ENTITIES 1-10, )
)
Defendants. )
)

DEMAND FOR JURY TRIAL

COMES NOW, Plaintiff ARNOLD LAANUI, JR., by and through his counsel

undersigned, and hereby demands trial by jury of all issues so triable herein.

DATED: Honolulu, Hawaii, August 2, 2024.

/s/ LEIGHTON M. HARA

LEIGHTON M. HARA
KALLISTA N. HIRAOKA

Attorneys for Plaintiff

ARNOLD LAANUI, JR.
 STATE OF HAWAI‘I SUMMONS
CIRCUIT COURT OF THE TO ANSWER CIVIL COMPLAINT /
FIRST CIRCUIT ____________________________________
CASE NUMBER

PLAINTIFF’S NAME & ADDRESS, TEL. NO.

Arnold Laanui, Jr.

c/o Leighton M. Hara, Esq. and Kallista N. Hiraoka, Esq.
737 Bishop Street, Suite 2860
Honolulu, Hawaii 96813
Telephone: (808) 532-1728

PLAINTIFF VS. DEFENDANT(S)

ARNOLD LAANUI, JR. THE CONGREGATION OF CHRISTIAN BROTHERS OF
HAWAII, INC., a Hawaii Corporation dba DAMIEN
MEMORIAL SCHOOL; JOHN DOES 1-10; JANE DOES 1-10;
DOE ENTITIES 1-10

TO THE ABOVE-NAMED DEFENDANT(S)

Leighton M. Hara, Esq. and Kallista N. Hiraoka, Esq.

737 Bishop Street, Suite 2860
Honolulu, Hawaii 96813
_______________________________________________________________________________________________,
Demand for Jury Trial

THIS SUMMONS SHALL NOT BE PERSONALLY DELIVERED BETWEEN 10:00 P.M. AND 6:00 A.M. ON
PREMISES NOT OPEN TO THE GENERAL PUBLIC, UNLESS A JUDGE OF THE ABOVE-ENTITLED
COURT PERMITS, IN WRITING ON THIS SUMMONS, PERSONAL DELIVERY DURING THOSE HOURS.

A FAILURE TO OBEY THIS SUMMONS MAY RESULT IN AN ENTRYOF DEFAULT AND DEFAULT
JUDGMENT AGAINST THE DISOBEYING PERSON OR PARTY.

Effective Date of 1-DEC-2021

Signed by: /s/ Patsy Nakamoto
Clerk, 1st Circuit, State of Hawai‘i

Form 1C-P-787 (12/21) 1CCT

Summons to Complaint