Bobby N. Harmon, CPCU, ARM

January 30, 2004

VIA fax only @ (559) 490-1919

Ms. Julie A. Schermerhorn, Supervisor, and

Mr. Justin W. Schuck, Case Manager

American Arbitration Association

6795 North Palm Avenue, 2^nd Ave.

Fresno, California 93704

RE: Mary Lou Woo, Trustee v. Bobby N. Harmon - Case No. 74 166 00491 03 JUSC

Dear Ms. Schermerhorn and Mr. Schuck:

This is in reference to my letter dated January 28, 2004, addressed to Clyde Mark, President of P&C Insurance Company, copies of which were sent to you and to Complainant.

With this letter, I hope to provide a compelling argument for the relevance and importance of full disclosure of the names of the insurance brokers and professional liability insurance carriers for the arbitrator, Judith Neustadter, as well as for Complainant Mary Lou Woo and her attorney, Steven Guttman.

The following chronology of correspondence related to this issue is revealing:

May 27, 2003

My initial letter to P&C Insurance Company, Inc., c/o Aon Insurance Managers, Attn: Jill Miura, tendering defense of this Arbitration claim. Aon did not respond.

June 16, 2003

My second notice to P&C, c/o Aon Insurance Managers, Attn: Jill Miura. Still no response from Aon; however...

June 20, 2003

Clyde Mark, President of P&C, replied to my June 16, 2003 letter, denying tender.

In his letter, Mr. Marks states:

“In response to your letter of May 27, 2003, P&C Insurance hereby rejects your tender of defense of the above entitled matter on the following grounds....

“Thus, if you continue to pursue this matter, P&C Insurance shall be entitled to indemnification from you and Mrs. Harmon for any and all damages and costs (including attorney’s fees) incurred in defense of any claim you bring “arising, arisen, growing out of, connected with of [sic] in any manner relating to the RELEASED CLAIMS. Any claim related to your employment as an officer or director of P&C Insurance is a RELEASED CLAIM.

“Accordingly, you are not entitled to coverage under any past or current insurance policy maintained by P&C Insurance. P&C Insurance hereby denies your tender of defense for the above-entitled arbitration P&C Insurance reserves all other objections and defenses to your tender of defense that have not be [sic] raised herein.”....

June 30, 2003

I responded to Clyde Mark’s letter of June 20, 2003, in part:

“Please allow me to point out that in my letter of May 27^th, I only asked, ‘Please have the company’s Claims Administrator contact me as soon as possible for further details and a copy of the Complaint.’ I find it highly incredulous that P&C would reject a tender of defense without requesting further information or obtaining a copy of the Complaint....

“There are a number of discrepancies that I find in your rejection letter.

“First, you do not provide the names, or give policy numbers and policy periods, for those insurance companies on whose behalf you are denying coverages. Therefore, as mentioned previously, I must demand complete copies of ALL policies for which you [are] denying my tender of defense.

“Second, I question if you have been authorized by all the insurance companies which issued these ‘past or current’ policies to act on their behalf as Claims Administrator. I find it highly unusual for the President of an insurance company to personally deny coverages. In the case of P&C, I have first-hand knowledge that P&C contracts out its Claims Administration to an independent adjuster – which in the past has been John Mullen & Co. Could you please explain why this case is not being handled through an independent adjuster, and would you please forward me copies of any and all claims authorization documents from those insurance companies on whose behalf you have acted to reject my tender of defense.

“Third, as I stated in my letter of May 27, 2003, my tender of defense is based upon the Indemnification Agreement afforded by P&C to all officers and directors of the company. Therefore, your review of this tender should be based on the Indemnification Agreement in this contract with P&C – not the Indemnification Agreement contained in the Settlement Agreement. In order to further pursue this issue, I ask that you please review the indemnification provisions in the contract that I originally signed as president of P&C, and that you send me a complete, signed copy of this Agreement for my review in preparation for the Arbitration proceedings.”...

July 7, 2003

Matt Tsukazaki’s letter to me in which he states:

“We have received copies of your May 27 and June 30, 2003 letters addressed to P&C Insurance Co., Inc. Please be advised that you should direct all of your future inquiries of and concerning Kamehameha Schools or P&C Insurance to my attention, and you should copy Mr. Steven Guttman, counsel for the Trustee of your bankruptcy estate, Ms. Mary Lou Woo, on any correspondence you send to me.

“In response to your June 30, 2003 letter, please be advised that pursuant to the Settlement, Release and Indemnification Agreement dated April 24, 2000, you released and waived any and all rights you had or may have had arising out of or based upon your employment with Kamehameha Schools or P&C Insurance. In addtion, as to all insurance carriers with whom Kamehameha Schools and/or P&C Insurance may have held an insurance policy, you expressly released these carriers and their agents from any responsibility to you under any policy.

“Accordingly, based upon the clear and specific language of the Settlement Agreement, you are not entitled to any defense of any claim brought against you by the Trustee of your own bankruptcy estate from Kamehameha Schools or P&C Insurance. You are also not entitled to indemnification from Kamehameha Schools, P&C Insurance or their insurance carriers, for any damages or costs you may suffer or incur in the Trustee’s action against you.

“Finally, based on the foregoing, you are not entitled to the information or documents you have requested in your June 30^th letter. If you continue to pursue this issue, as provided for under the Settlement Agreement, Kamehameha Schools will seek indemnification for any and all attorney’s fees and costs it incurs in responding to your groundless and frivolous claims and allegations.”

July 28, 2003

I wrote a letter to P&C Insurance Co., c/o Jill Miura, Aon Insurance Managers, which stated in part:

“On May 27, 2003, I tendered defense of the above claim to P&C Insurance Company, Inc., as provided for in the Indemnification Agreement afforded to me as a former officer of the company. I also asked that you have P&C’s Claims Administrator contact me as soon as possible for further details and a copy of the complaint. To date, I have not been contacted by P&C’s authorized Claims Administrator.

“On May 28, 2003, I transmitted to you a copy of the American Arbitration Association’s letter dated May 27, 2003, noting that the Response Due Date to their letter was on or before June 6, 2003. I received no response from you or P&C’s Claims Administrator to this letter.

“On June 16, 2003, I sent to you a second notice of tender which stated: “As the arbitration process is set to begin within the next few days, I again request that P&C’s Claims Administrator contact me as soon as possible for further details.”

“In a letter dated June 20, 2003, Clyde Mark, President of P&C Insurance Company, Inc., wrote, in part:

‘In response to your letter of May 27, 2003, P&C Insurance hereby rejects your tender of defense of the above entitled matter on the following grounds....’

“On June 30, 2003, I responded to Mr. Mark, in part, as follows:

“Mr. Mark did not respond to this letter. Instead, I received a letter from Matt A. Tsukazaki, of the law corporation of TORKILDSON, KATZ, FONSECA, JAFFE, MOORE & HETHERINGTON, in which he stated, in part:

‘We have received copies of your May 27 and June 30, 2003 letters addressed to P&C Insurance Co., Inc. Please be advised that you should direct all of your future inquiries of and concerning Kamehameha Schools or P&C Insurance to my attention, and you should copy Mr. Steven Guttman, counsel for the Trustee of your bankruptcy estate, Ms. Mary Lou Woo, on any correspondence you send to me.’...

“Mr. Tsukazaki sent a courtesy copy of this letter only to Steven Guttman. He does not indicate that a copy was sent to anyone at Kamehameha Schools or P&C Insurance Company. There is no indication of copies being sent to their insurance carriers that Mr. Tsukazaki claims to represent, and on whose behalf he is denying coverages. Also, no copy was sent to the American Arbitration Association. Finally, there is no indication that a copy was sent to your office or to P&C’s authorized, independent Claims Administrator.

“On July 7, 2003, I responded to Matt Tsukazaki’s letter, in which I stated, “In order for me to honor this request, I will require that your first provide me with copies of Attorney of Record letters from both Kamehameha Schools and P&C Insurance Company, Inc. authorizing your previous representation in my RICO and wrongful termination cases as well as for the Arbitration matter at hand.”

“I further advised Mr. Tsukazaki, ‘I will respond to the remainder of your letter of July 7^th, once I have received evidence of these Attorney of Record letters.’

“Since I have not received a response from Matt Tsukazaki to my July 7^th letter, I am addressing the following requests to your office as P&C’s captive insurance company manager:

1. Please advise me of the name, address, and facsimile number of P&C’s current, independent Claims Administrator.

2. Provide the name, address, and facsimile number of the independent Claims Administrator that was responsible for the handling of my prior Wrongful Termination and RICO lawsuits.

3. Provide me a copy of P&C ’s Indemnification Agreement that indemnifies and holds harmless all officers and directors of P&C Insurance Company, which I signed upon becoming President of P&C.

4. Submit my Tender of Defense directly to P&C’s current, independent Claims Administrator, and provide me a copy of your transmittal letter to this administrator.

“Your immediate response is requested.”

No response to this letter was ever received – not even notification from Aon that they were no longer the Captive Manager for P&C.

August 15, 2003

My letter notifying you that on August 14, 2003, I had filed a Complaint against P&C Insurance Company, Inc., Clyde Mark and Matt Tsukazaki, with the Insurance Division, State of Hawaii, for refusing to accept my tender of defense in the instant arbitration case. In this letter, I stated:

“The fact that Mr. Tsukazaki, purportedly on behalf of P&C, has declined to accept my tender of defense and has also improperly refused to provide me with a copy of my contract with P&C, it becomes necessary for me to request that proceedings in the subject Arbitration case be placed on hold until such time as the Insurance Division, State of Hawaii, has had time to act on my complaint.”

August 18, 2003

Steven Guttman’s letter to you in which he stated:

“The Trustee objects to Mr. Harmon’s request to place the arbitration ‘on hold until such time as the Insurance Division, State of Hawaii, has had time to act on (his) complaint.’ Mr. Harmon has been told he does not have insurance coverage and his complaint to the State of Hawaii Insurance Division will not affect the decision of the insurance company.

“Mr. Harmon was able to delay the commencement of the arbitration for approximately five and one-half months based upon his frivolous objections to various individuals proposed by the AAA to serve as arbitrators. Now that an arbitrator has finally been selected, Mr. Harmon apparently wants to continue to pursue his own agenda through the Hawaii regulatory agency and encumber the arbitration process with further delays. Independent of the merits (or lack thereof) of his insurance arguments, the State of Hawaii’s complaint regulatory process will have no effect on his obtaining insurance coverage for his actions subsequent to his employment termination and entering into the settlement agreement that is the subject of the arbitration..

“Mr. Harmon’s request should be denied and the Claimant shoud be allowed to proceed on the merits of this pending arbitration.”

August 19, 2003

My letter to you in response to Guttman’s letter of August 18, 2003:

“The statements regarding my complaint and the effect on my obtaining insurance coverages are inaccurate and untrue. My complaint to the Insurance Commissioner concerns a legal issue – not a coverage issue. Insurance companies licensed to do business in Hawaii are subject to regulation by the State of Hawaii Insurance Division. One such regulation is that insurance claims must be administered by a State-licensed Insurance Adjuster. To my knowledge, neither Clyde Mark nor Matt Tsukazaki are licensed Adjusters for P&C Insurance Company, Inc., or for the insurance companies they refused to name. If my understanding is correct, then P&C has engaged in unfair claims practices and is in violation of Hawaii’s Insurance Statutes....”

“Even after all these months, Mr. Guttman still has not produced any evidence that these attorneys, including Matt Tsukazaki, were the legal Attorneys of Record in these lawsuits which Mr. Guttman “settled” on behalf of the Trustee. I still maintain that, in the interests of fairness, expediency and cost-effectiveness, Mr. Guttman should produce this evidence prior to the start of the arbitration hearings.

“In the case of Matt Tsukazaki, Mr. Guttman would have you overlook the fact that Tsukazaki has claimed to be not only the Attorney of Record for Kamehameha Schools and P&C Insurance Company, Inc., but also the Claims Adjuster for P&C as well as other, unnamed insurance companies on whose behalf Mr. Tsukazaki has denied my claims. To me, speaking from my experience as an insurance professional and not an attorney, this literally shouts, “Fraud,” “Conflicts of Interest,” “Bad Faith,” and “Unfair Claims Practices.” However, this is ultimately for the Insurance Commissioner to decide – not me or Mr. Guttman.

“As far as this unduly delaying the arbitration process, as Mr. Guttman maintains it would, my basic question to the Insurance Commissioner is whether or not Clyde Mark and Matt Tsukazaki are licensed Claims Adjusters. I believe this would require but a few days to answer. If the Commissioner’s answer is, “YES, they are licensed Claims Adjusters,” then I would agree that this particular issue is resolved.

“If the Commissioner’s answer is, “NO,” however, then I would contend that the arbitration should not proceed–at least until such time P&C’s legitimate, licensed Claims Adjuster has had the opportunity to review this case and render his coverage decision. For the AAA to commence the arbitration proceedings while I am still in the process of contesting the validity of the insurance company’s denial of coverages, would give an unfair advantage to the Complainant in this case and should not be allowed. “

August 19, 2003

Mr. Guttman’s letter to you:

“... If Mr. Harmon does not timely pay the recent billing, please telephone me to discuss alternative arrangements to address his financial obligation.

“For the reasons set forth in our letter to you dated August 18, 2003, the Trustee adamantly objects to Mr. Harmon’s continuing attempts to any further delay this proceeding. His request to place the arbitration ‘on hold until such time as the Insurance Division, State of Hawaii, has had time to act’ should be denied and the Trustee should be allowed to proceed on the merits of this pending arbitration....”

August 20, 1993

My letter to you in response to Guttman’s letter of August 19, 2003:

... “Mr. Guttman is, again, apparently missing the point. The reason for my complaint to the Insurance Division was due to the fact that my claim to P&C Insurance Company was denied by Matt Tsukazaki of Torkildson, Katz, et al. P&C and Torkildson Katz were both defendants in my Racketeer-Influenced Corrupt Organizations (RICO) lawsuit, along with Kamehameha Schools Bishop Estate and Nathan Aipa, their General Counsel and an officer of P&C. Matt Tsukazaki, to the best of my knowledge, is NOT a licensed Claims Adjuster, so his denial of my claim constitutes fraud, and is not a valid declination. If P&C’s authorized, licensed Claims Adjuster (and NOT Matt Tsukazaki) had denied my claim, then it would not have been necessary for me to submit my Complaint to the Hawaii Insurance Commissioner and request a postponement until this matter can be resolved.

“Or, to put it another way, if Mr. Guttman had done his job properly three years ago, from the very start of our bankruptcy proceedings, and had requested evidence in the form of Attorney of Record letters and copies of Adjuster’s Licenses, to verify that these attorneys were, in fact, authorized to act on behalf of P&C Insurance Company, all five of the issues in Trustee Woo’s Complaint would never have arisen.

“Even at this late date, Trustee Woo and Mr. Guttman can avoid further unnecessary delays if they will provide the requested Attorney of Record letters and evidence that Matt Tsukazaki and Clyde Mark are, in fact, licensed Claims Adjusters....”

August 25, 2003

Mr. Guttman’s letter to you:

“At to Mr. Harmon’s commentary concerning my letter dated August 18, I note that Mr. Harmon concedes ‘that the Insurance Division does not have the authority, nor are they being asked, to make a coverage decision’ ...

“Although Mr. Harmon states that he wants to delay the AAA proceedings while he is ‘still in the process of contesting the validity of the insurance company’s denial of coverages,’ his own letter acknowledges that the Insurance Division will not address the issue of whether his own intentional actions fall within the parameters of the insurance ‘coverages’. As I previously stated, there is no legitimate basis to postpone the arbitration.’

“In light of the many letters sent by Mr. Harmon to the AAA, I am astonished by his comment that the delay in this matter is due to my ‘insistence upon selecting an arbitrator who would appear not to meet AAA’s requirements for experience and neutrality that has been the real cause of these delays....”

“I reiterate my prior comments as to Mr. Harmon’s correspondence regarding Ms. Neustadter and the AAA proceeding with the arbitration. There is nothing in any of his letters which establishes that Ms. Neustadter has any conflict regarding this case.” ...

August 26, 2003

My letter to you in response to Guttman’s of August 25, 2003:

“... Once again, Mr. Guttman totally misconstrues my point about the Insurance Division not being asked to make a coverage decision. As I stated in my August 19^th letter, ‘My complaint to the Insurance Commissioner concerns a legal issue - not a coverage issue. Insurance companies in Hawaii licensed to do business in Hawaii are subject to regulation by the State of Hawaii Insurance Division. One such regulation is that insurance claims must be administered by a State-licensed Insurance Adjuster. To my knowledge, neither Clyde Mark nor Matt Tsukazaki are licensed Adjusters for P&C Insurance Company, Inc., or for the insurance companies they refused to name. If my understanding is correct, then P&C has engaged in unfair claims practices and is in violation of Hawaii’s Insurance Statutes.”

“Stated another way, the point I am making here is that I was not requesting that the arbitration be delayed until the Insurance Commissioner had made a coverage decision. I was simply requesting a postponement until such time as the Commissioner - the proper authority in this case - had provided factual information regarding the licensing of these two individuals. If the answer is a simple ‘YES, they are licensed,’ then this disputed issue would be resolved. If the answer to this factual question is ‘NO,’ however, then it would appear that P&C is in violation of Hawaii Statutes, and Mr. Marks and Mr. Tsukazaki may have committed fraud, and the declination letters they issued in this case are invalid. Then the true, legitimate adjusters for P&C would need to reassess their coverage position and respond to my tender of defense. Contrary to Mr. Guttman’s contention, I believe this should be considered a legitimate basis to postpone the arbitration, at least until the Insurance Commissioner has had the opportunity to respond to my ‘yes’ or ‘no’ question regarding the licensing of these individuals.

“Mr. Guttman also completely disregards my contention: ‘Even after all these months, neither Mr. Guttman nor the attorneys involved, have produced any evidence that these attorneys including Matt Tsukazaki, were the legal Attorneys of Record in these lawsuits which Mr. Guttman ‘settled’ on behalf of the Trustee. I still maintain that, in the interests of fairness, expediency and cost-effectiveness, Mr. Guttman should produce this evidence prior to the start of the arbitration hearings.’...

“Again I would ask that Ms. Neustadter, and not Mr. Guttman, make full disclosure as respects actual and potential conflicts-of-interest with the individuals, companies and organizations that I named in previous letters, as well as any other entities that I did not single out, but with whom Ms. Neustadter may be conflicted.

“Also, in the interests of fairness and expedience, I would ask that these disclosures be made, in writing, by Ms. Neustadter prior to the commencement of these proceedings.” ...

September 19, 2003

My letter to you:

“This responds to your letter dated September 18, 2003, in which you state regarding my letters of August 26, September 8, 15 and 17, 2003, and Steven Guttman’s letter of September 15, 2003: “After careful consideration of the parties’ contentions, the Association has determined that Judith Neustadter, Esq. will be reaffirmed as the arbitrator in the above matter.”

“As I have stated in previous letters, there are many additional connections that I can offer to illustrate why Judith Neustadter’s position on the Maui Planning Commission should disqualify her as neutral arbitrator, but that it was my belief that the ones I had described should be sufficient. Since this, unfortunately, is not the case, I feel it is necessary to offer these additional comments to further support my request that Ms. Neustadter be disqualified.

“In my letter of September 15, 2003, I gave details on the connections of Insurance Commissioner J.P. Schmidt to Maui County. In my letter of September 17^th, I presented facts regarding the connections of Colbert Matsumoto to Kamehameha Schools and Hawaii’s Land Use Commission. This letter will identify further individuals and organizations that have similar conflicting personal, political and financial connections to this case:

Torkildson Katz Fonseca Moore & Hetherington

“This law firm, which was named in my RICO lawsuit, and which falsely claims to be the authorized Claims Administrator for P&C Insurance Company in this arbitration matter, has also represented the County of Maui in federal court matters. To cite just one example: Casino et al. V. Inter-State Pharmacy Corp...

Guido Giacometti and Susan Tius

“Guido Giacometti was the former head of Kamehameha Schools’ Asset Management Division; the former CEO for Grove Farm; and is the current bankruptcy trustee for Sukamto Sia. He is also the husband of Susan Tius who represented Kamehameha Schools in our bankruptcy case.

“Susan Tius is also one of the individuals who I am claiming has a conflict of interest with Trustee Mary Lou Woo in this case. This conflict is one of the issues to be decided by this arbitration.

“Susan Tius is also the attorney representing the Maui Home Supply bankruptcy estate. According to newspaper accounts, the Maui Home estate has hired the firm of Sterling & Tucker Inc. to help search for missing assets, but has yet to recover any...

Jeffrey H. Case

“From an Aon Risk Services Companies press release dated October 23, 1999:

‘Jeffrey H. Case has joined the downtown Honolulu offices of Aon Risk Services Companies Inc, as executive vice president in charge of marketing....

‘Case was previously vice president of Marsh Risk & Insurance Services, based in San Francisco....

‘Aon Risk Services Companies, Inc. is a subsidiary of Aon Corporation, a Fortune 500 company....

“Aon Risk Services is the current Captive Manager for P&C Insurance Company, and was the office to which I submitted my Tender of Defense for the instant arbitration. Aon did not respond to my earlier claims against subsidiaries of Kamehameha Schools. When I submitted my Tender of Defense to them, they did not forward it to P&C’s independent claims adjuster, as is required. Instead, I received an initial response from Clyde Mark, President of P&C, who denied my tender. Later, I received a second declination from Matt Tsukazaki, of Torkildson Katz, who claimed to be representing both Kamehameha Schools and P&C Insurance Company in this matter. Consequently, Aon is also involved in my Complaint to Hawaii Insurance Commissioner J.P. Schmidt.

“Aon took over the captive management duties for P&C from Marsh & McLennan which was another named Defendant in my RICO lawsuit.”...

October 6, 2003

Mr. Guttman’s letter to you:

“This letter responds to your communication dated September 24, 2003, seeking our comments to Mr. Harmon’s request that this proceeding be held in abeyance.

“It is our position that this proceeding should NOT be held in abeyance. We believe the arbitration should proceed without further delays. We maintain that Judith Neustadter serving as the arbitrator in this case does not raise any conflict of interest issues.”

As finally revealed by Lori Chung in her letter of January 26, 2004, Aon’s management contract with P&C Insurance Company was terminated on June 30, 2003. This now explains why the denial of my claim improperly came from Clyde Mark, president of P&C, and Matt Tsukazaki, of Torkildson Katz Fonseca Moore & Hetherington, rather than from P&C’s authorized Claims Adjuster, and why my subsequent requests to Aon Insurance Managers and John Mullen & Company were never answered.

I believe this new information also provides further evidence of deception, bad faith, fraud, conspiracy to commit fraud, and other wrongful acts by Kamehameha Schools; Colleen Wong; Louanne Kam; P&C Insurance Company; Clyde Mark; Marsh & McLennan; Aon Insurance Managers; John Mullen & Company; Matt Tsukazaki and Robert Katz, of Torkildson Katz Fonseca Moore & Hetherington; Susan Tius, of Rush Moore Craven Sutton Morry & Beh; Kenneth Hipp, of Marr Hipp Jones & Pepper; Island Insurance Company; Bradley Tamm, Esq.; Greg Dunn, Esq.; Mary Lou Woo, Trustee; her attorney, Steven Guttman, Esq.; and other companies and individuals.

Over the months and years, I have filed a number of professional liability claims related to misrepresentation, fraud and conspiracy to commit fraud in this case. The following is a partial listing of these claims and their “claims made” dates:

06/24/02 Kenneth Hipp and Marr Hipp Jones & Pepper

12/12/03 Bradley Tamm and Greg Dunn

12/12/03 Steven Guttman and Kessner Duca Umebayashi Bain & Matsunaga

12/12/03 Trustees of Kamehameha Schools, Colleen Wong, Louanne Kam, Maryanne Inouye, Nathan Aipa, Clyde Mark, Rodney Park, their Attorneys and Independent Contractors, et al.

12/12/03 Susan Tius and Rush Moore Craven Sutton Morry & Beh

12/12/03 Matt A. Tsukazaki, Robert Katz, Sabrina Toma and Torkildson Katz Fonseca Jaffe Moore & Hetherington

01/27/04 Aon Insurance Managers

To date, I have received no response to any of these claims. With the exception of the most recent claim against Aon Insurance Managers, written acknowledgments of these claims by the entities’ insurance carriers are overdue. This is indicative of further conspiracies between these parties and their insurance companies, or, with the exception of Tamm, a failure of these entities to report these claims to their carriers.

As these frauds and deceptions have already resulted in months of delays and thousands of dollars in expenses, with no end in sight of Claimant’s denials of conflicts and other delaying tactics, I would suggest that the AAA take immediate and appropriate action to put a halt to these arbitration proceedings – if not permanently, then at least until such time as these outstanding insurance and conflict-of-interests issues have been fully resolved.

Thank you for your careful consideration of this request.

Sincerely yours,

Bobby N. Harmon

cc: Mary Lou Woo, Trustee, c/o Steven Guttman, Esq.

Kessner, Duca, Umebayashi, Bain & Matsunaga

VIA fax only @ 808-529-7177