DECLARATION OF DAVID LAEHA
I, DAVID LAEHA, do hereby declare:
1. I am an employee of the State of Hawaii and the Chief Financial Officer of the Office of Hawaiian Affairs ("OHA").
2. I am also a Manager of Hi'ilei Aloha, LLC ("Hi'ilei"), Ho'okele Pono LLC (''Ho'okele Pono''), and Hi'ipaka LLC ("Hi'ipaka") (collectively, the "Respondents").
3. This Declaration is in support of Respondents' Supplemental Briefing.
4. As a matter of practice, the Managers restrict the Office of Hawaiian Affairs' ("OHA") access to the information of the Respondents so as to reserve managerial powers in the Managers, as contemplated in Respondents' operating agreements. Managers have explicitly limited OHA's access to information, and reserved their right to continue to do so….