My (more) Discovery plan. If necessary, I may continue discovery with depositions (Subpoena Duces Tecum) on Ms. Hanabusa, Chief Election officer, Mr. Nago, and Attorney General, Mr. Suzuki, depending on how they respond to my initial discovery questions.
Aloha.
P.S. Today, I am serving one more entity, US Attorney General, Complaint and Summons.
So, Certificate of Service with corrected sevice list for the complaint and summons will be mailed out to all parties, accordingly. Thanks.
In Trump-Kim Singapore summit on June 12, 2018, we may not see a big breakthrough, like end of Korean war, although it may happen in later date at different location; since President Trump might have chosen a gradual and step-by-step approach. (Source: JTBC)
So, the summit may be just reiteration of their previous agreements and photo-ups, although may still produce positive result (but, not much).
Aloha.
Sua Sponte may be another possibility.
The court may make own motion, (e.g. to transfer directly to Supreme Court).
But, if happens, the court may want to make own motion for summary judgment to expedite the case.
However, I would not want to accept this motion, unless the court decides to make me win and disqualify Ms. Hanabusa right away; (since, my complaint basically already has all needed facts and evidence to get ruling in my favor).
However, it may not be easy for court to rule against me with this own motion, esp. pending the discovery on the defendants and Ms. Hanabusa, (not to mention strong merits in my case). Because, if happens, this would violate my due process, fundamental basic right; and, I doubt the court would likely do this.
However, if the attorney general or the election office is to disqualify Ms. Hanabusa, then, they may want to use this route to expedite the process.
Aloha.
Now, Defendants may want to prepare how and what to respond to my complaint.
Among other things, they may want to think of some pre-answer motions in order not to respond with answer, especially because they may also want to avoid or not respond to my discovery questions.
So, I may have to plan and prepare (study), in case, since we may only have some limited time to respond.
However, having good triable issues clearly present in the case, they may not have much choice but to respond with answers to Complaint and discovery, since any of their attempt to file pre answer motions like motion to dismiss may mostly not succeed, (assuming Judge(s) are reasonable).
Well, I also need to prepare for Meet and Confer, if the opponents are open for any negotiations; in this case, nothing much to negotiate, except Ms. Hanabusa withdrawing from her candidacy for governor. But, Court always like to hear of many ways of communication between parties.
Aloha.
Today, I received the return postcards from both defendants, State Attorney General and The election office.
This may mean process service (of Complaint and Summons) may have been done on them.
I am still waiting for the same things from Ms. Hanabusa’s offices (Real Parties in Interest) in Washington DC (US Congress) and in Honolulu (from Hanabusa for Governor); (and, I sent a service copy to her other Honolulu office for US Congress, just via 1st class mail).
Aloha.