Harmon Preliminary Witness List

www.the-catbird-seat.net/BH-CHRON-97-99.htm

www.the-catbird-seat.net/DOCS-PC-Coopers-11-20-96.htm

www.the-catbird-seat.net/EQ2048-AG-Trustees-4-27-0.pdf

www.the-catbird-seat.net/Claims-Branch-Kamehameha.htm

www.starbulletin.com/97/09/19/news/satnews.html

www.starbulletin.com/1999/05/10/news/story6.html

www.starbulletin.com/2000/05/24/news/story4.html

www.starbulletin.com/2000/07/03/news/story1.html

www.starbulletin.com/2002/05/16/news/story4.html

LISSA H. ANDREWS

Attorney for Federal Insurance Company (Chubb Group) in Equity No. 2048, Judge Kevin Chang, presiding, and attorney for Federal Insurance Company in CV99-00304-DAE (the “RICO” lawsuit).

Rush Moore Craven Sutton Morry & Beh

Hawaii Tower, 20^th Floor

745 Fort Street

Honolulu, HI 96813

This witness is expected to testify about her, and her firm’s, relationships with Kamehameha Schools/Bishop Estate; her dual roles as the attorney for Federal Insurance Company (Chubb Group) in EQ2048, Judge Kevin Chang presiding, and as the attorney representing Federal Insurance Co. in Harmon’s RICO lawsuit CV99-000304-DAE, before Judge David A. Ezra and Magistrate Judge Barry Kurren. Regarding these two lawsuits, Lissa Andrews is expected to testify as to the dates the two claims were first reported to Federal Insurance Co.; the policy number and policy period of Federal’s policy; the name of the person, or persons, reporting these claims to Federal; the name and address of Federal’s Claims Adjuster(s) responsible for adjusting these claims; the name of Federal’s representative who signed the Settlement Agreement, and the date signed. This witness is also expected to produce a copy of the reported “side letter” to the Agreement between Federal and other unknown parties to the Agreement, which undisclosed document Harmon claims was a breach of the Settlement Agreement.

Internet Reference:

www.the-catbird-seat.net/Claims-Branch-Rush-Moore.htm

www.the-catbird-seat.net/Claims-Branch-Chubb.htm

EARL ANZAI

Former Hawaii Attorney General.

Address To Be Determined

This witness is expected to testify as to the facts and circumstances regarding his role in EQ2048, and Defendant Harmon’s testimony as a witness in that case. He is also expected to testify regarding the insurance settlement negotiations with Kamehameha Schools, P&C Insurance Company, Marsh & McLennan, Federal Insurance Co. (Chubb), XL Insurance, AmRe and any other insurance agents, claims adjusters or insurance carriers involved in EQ2048 and any related cases involving Kamehameha Schools trustees, employees or independent contractors. Mr. Anzai will be expected to describe any business, professional, family and social relationships with Lyn Flanigan Anzai, Colleen Wong, Louanne Kam, Guido Giacometti, Yukio Takemoto, Gilbert Tam, William S. Richardson, Richard Wong, Clayton Hee, Steven Guttman, Calvin Say, Hugh Jones, Dorothy Sellers, Kevin Wakayama, Benjamin Cayetano, University of Hawaii, Hawaiian Airlines, and others yet to be named. Also, Mr. Anzai will be expected to provide copies of all documents and correspondence that Defendant has provided to the Office of the Attorney General regarding any cases relating to Kamehameha Schools Bishop Estate, and a copy of my witness deposition that was given to private investigator Steve Goodenow of Goodenow Associates Inc., in the presence of Deputy Attorney Generals Hugh Jones and Dorothy Sellers.

Internet References:

www.starbulletin.com/2000/03/09/news/story/5.html

LYN FLANIGAN ANZAI

Former internal attorney for Kamehameha Schools Bishop Estate

Hawaii State Bar Association

1132 Bishop St., Suite 906

Honolulu, HI 96813

Fax: 808-521-7936; e-mail: lflanigan@hsba.org

This witness is expected to testify about her relationships with Defendant, Trustees of Kamehameha Schools, Colleen Wong, Nathan Aipa, Rocco Sansone (Marsh & McLennan), Alan Yee, former Attorney General Earl Anzai, Dennis Fern, and others, with regard to tax fraud, violation of IRS Section 4958, bogus-bid contracts, Obstruction of Justice in EQ2048, and other wrongful acts.

Internet References:

www.the-catbird-seat.net/INTERROGATORIES.htm

www.the-catbird-seat.net/Paradise.htm

BOB AWANA

Hawaii Governor Linda Lingle’s Chief of Staff; former Chief of Staff to Honolulu Mayor Eileen Anderson; former Government Affairs Director, Waste Management, Inc.; former regional vice president Village Resorts, Inc.; former assistant vice president, Bank of Honolulu; former agent, First Insurance Company.

Office of the Governor

Honolulu, Hawaii

This witness is expected to provide testimony regarding his relationships with Governor Linda Lingle; Mark Recktenwald, Director of the Department of Commerce & Consumer Affairs; Marr Hipp Jones & Pepper; J.P. Schmidt, Hawaii Insurance Commissioner; Judith Neustadter Fuqua; Maui County; Mark Bennett, Hawaii Attorney General; Bank of Honolulu; Sukamto Sia; Diane J. Plotts; Donna Tanoue; Bank of the Orient; Guido Giacometti; Unity House; Anthony Rutledge, Sr.; Tony Rutledge; Romeo Mindo; Colleen Hanabusa; Michael Green; Eric Seitz; Waste Management, Inc.; Gary Rodrigues; Robert Katz and John L. Knorek of Torkildson Katz Jossem, Fonseca, Jaffe, Moore & Hetherington; William McCorriston, Mark J. Bennett, and Nadine Ando of McCorriston, Miho & Miller; former Honolulu Mayor Eileen Anderson; Benjamin Matsubara; Ralph Englestad; George Ariyoshi; Wayne Minami; Kamehameha Schools Bishop Estate; First Insurance Company; Paul Brown, Lena Awana; VHY Insurance, and others yet to be named.

Internet References:

www.the-catbird-seat.net/Act221.htm

www.the-catbird-seat.net/Claims-Branch-Commissioners.htm

www.the-catbird-seat.net/Claims-Branch-Torkildson-Katz.htm

www.the-catbird-seat.net/Claims-Branch-Marr-Hipp.htm

www.the-catbird-seat.net/Claims-Branch-AttorneyGeneral.htm

ANDREW BOYLES

Bank of Hawaii employee, Service Representative and Investment Advisor to P&C Insurance Company.

Bank of Hawaii

Bishop Street

Honolulu, HI 96813

Tel: 808-537-8442

This witness is expected to testify as to any banking or other financial relationships any of the Kamehameha Schools or P&C officers, directors, trustees, employees, or independent contractors, may have had with co-investors in any private or commercial investments, and, in particular, with McKenzie Methane, and Ko Olina Partners.

Internet References:

www.the-catbird-seat.net/INTERROGATORIES.htm

www.the-catbird-seat.net/Ko-Olina.htm

MARGERY BRONSTER

Former Hawaii Attorney General

Bronster Crabtree & Hoshibata

1001 Bishop St., 2300 Pauahi Tower

Honolulu, HI 96813

Fax: 808-599-1881; Email: info@bchlaw.net

This witness is expected to testify about the facts and circumstances of EQ2048, and the testimony of Defendant as a witness in that case.

Internet Reference:

www.starbulletin.com/98/09/11/news/story2.html

MICHAEL CHERKASKY

CEO, Marsh & McLennan Companies

Marsh & McLennan Companies

1166 Avenue of the Americas

New York, NY 10036-2774

This witness is expected to testify regarding Marsh & McLennan’s alleged practices of bribery, bid rigging, over-charging, kickbacks, and other wrongful acts. As a “Real Party in Interest” and a recipient of Harmon’s letters, he is expected to testify regarding Harmon’s alleged “letter writing campaign”, including how this “campaign” violated the terms of the Settlement Agreement, and what damages Marsh & McLennan sustained as a result of the alleged campaign.

Internet References:

www.the-catbird-seat.net/MM-Mercer.htm

www.the-catbird-seat.net/MM-Putnam.htm

www.the-catbird-seat.net/Claims-Branch-Marsh-McLennan.htm

WALLY CHIN

Comptroller, Kamehameha Schools; Recipient of letters in Harmon’s “letter-writing campaign.”

Kamehameha Schools

567 S. King Street

Honolulu, HI 96813

This witness is expected to testify as to the facts regarding Harmon’s employment at Kamehameha Schools; Harmon’s entitlement to Retirement Plan; KSBE’s legal requirements for reporting employee wage income to IRS on Forms W-2 and 1099-R.

Internet Reference:

www.the-catbird-seat.net/IRS-Intermediate-Sanctions.pdf

www.the-catbird-seat.net/Aon.htm

MIKE COULTER

Deputy Managing Director

Aon Insurance Managers

201 Merchant Street, Suite 2400

Honolulu, HI 96813

This witness is expected to testify as to the facts and circumstances regarding Aon’s role in the failure to respond to Harmon’s Tender of Defense to P&C Insurance in the Arbitration, and to provide the following information regarding this Claim: The Name, Address, Policy Number, Policy Period of the applicable insurance carrier for this claim; their assigned Claim Number and Claim Made Date; and the Name and Address of the independent, licensed Claims Adjuster for this Claim.

Internet References:

www.the-catbird-seat.net/Claims-Branch-Aon.htm

JAMES DUFFY

Former Kamehameha Schools Master; Mediator in EQ2048; Attorney in the firm of Fujiyama, Duffy & Fujiyama; Clients have reportedly included Colbert Matsumoto, Island Insurance Co.; Herbert Horita’s Halekua Development Corporation.

This witness is expected to testify as to the facts and circumstances regarding his role in the insurance settlement negotiations with Kamehameha Schools, P&C Insurance Company, Marsh & McLennan, Federal Insurance Co. (Chubb), XL Insurance, Ace, and others in EQ2048. Mr. Duffy is also expected to testify as to his professional, financial and social relationships, if any, with Herbert Horita, Halekua Development, Ko Olina Resort & Marina, Jeffrey Stone, Richard Wong, Henry Peters, Kevin Showe, National Housing Corp., National Mortgage Co., Island Insurance Company, Colbert Matsumoto, AIG Hawaii, Robin Campaniano, Sidney Ayabe, Office of Hawaiian Affairs, Benjamin Cayetano, Larry Mehau, Hawaii Protective Association, the Harry & Jeanette Weinberg Foundation, the State Land Use Commission, Governor Linda Lingle, Jeremy Harris, Mark Bennett, Earl Anzai, Margery Bronster, Wallace Fujiyama, Steven Guttman, John D. Marshall, Esq., and others yet to be named.

DENNIS FERN

President, Kukui Inc.; former Internal Auditor for Kamehameha Schools Bishop Estate.

c/o Kamehameha Schools

567 S. King Street

Honolulu, HI 96813

This witness is expected to testify regarding IRS regulations, conflicts of interests and violations of “arms-length” requirements between Kamehameha Schools and Kukui Inc. - the owner of the former McKenzie Methane.

Internet References:

www.starbulletin.com/2002/05/23/news/story2.html

www.the-catbird-seat.net/Claims-Branch-Kamehameha.htm

JUDITH NEUSTADTER FUQUA

Arbitrator assigned by the American Arbitration Association in Woo vs. Harmon.

This witness is expected to testify regarding the facts and circumstances in the Arbitration proceedings, and her business, professional, family and social relationships, if any, with the Maui Planning Commission, Kamehameha Schools/Bishop Estate, Hamilton McCubbin, Lyn Anzai, Nathan Aipa, Colleen Wong, Susan Tius, Guido Giacometti, Paul Alston, Alston Hunt Floyd & Ing, Gensiro Kawamoto, CB Richard Ellis, Gene & Nora Lum, Ron Brown, John Waihee, Alexander & Baldwin, J.P. Schmidt, Marsh & McLennan, John Mullen & Co., Prudential, Royal SunAlliance Insurance, Gil Tam, Robert Kihune, Sandwich Isles Communications, Summit Communications, Judge Samuel King, Judge Kevin Chang, Judge David Ezra, and others yet to be named.

Internet References:

www.the-catbird-seat.net/AAA-12-15-3.htm

www.the-catbird-seat.net/GensiroKawamoto.htm

www.the-catbird-seat.net/CBRichardEllis.htm

www.the-catbird-seat.net/Developers.htm

www.the-catbird-seat.net/YAKUZA.htm

www.the-catbird-seat.net/MaunawiliValley.htm

www.the-catbird-seat.net/WeinbergFoundation.htm

www.the-catbird-seat.net/Alexander-Baldwin.htm

www.the-catbird-seat.net/HarmonArbitration.htm

www.the-catbird-seat.net/Claims-Branch-AAA.htm

GUIDO GIACOMETTI

Former executive for Kamehameha Schools/Bishop Estate; currently does work for Kamehameha Schools’ for-profit subsidiary; husband of Susan Tius.

Address to be determined.

This witness is expected to testify as to his relationships to Susan Tius; Sukamto Sia; Gil Tam; Henry Peters; Richard Wong; Nathan Aipa; Colleen Wong; Louanne Kam; Robert Katz; Matt Tsukazaki; Gensiro Kawamoto; Carol Asai-Sato; Paul Alston; Alston Hunt Floyd & Ing; CB Richard Ellis; McKenzie Methane; Marsh & McLennan Companies; Maui Planning Commission, Mary Lou Woo; Steven Guttman, others. He will be asked to testify about his investments in McKenzie Methane, preferential treatment of certain Bishop Estate lessees, improper or illegal activities such as, political lobbying by KSBE trustees and employees, kick-backs, tax fraud, etc.

Internet References:

www.the-catbird-seat.net/IRS-Intermediate-Sanctions.pdf

www.the-catbird-seat.net/GensiroKawamoto.htm

www.the-catbird-seat.net/CBRichardEllis.htm

JOHN GOEMANS, Esq.

Attorney for Bobby Harmon in his “whistle-blower” countersuit against Kamehameha Schools Bishop Estate and P&C Insurance Company, Inc.; attorney in Rice vs. Cayetano case, and in Mohica-Cummings vs. Kamehameha Schools, challenging Kamehameha’s racial admissions policy.

P.O. Box 2849

Kamuela, HI 96743

Tel No. 808-937-9111

This witness is expected to testify as to the facts regarding Harmon’s “Whistle-blower” lawsuit, and his relationships with the Kamehameha Schools Trustees; Jim Dooley; Sally Apgar; Rick Daysog; Bruce Dunford; and the Office of Hawaiian Affairs (OHA).

STEVEN GUTTMAN, Esq.

Attorney for Mary Lou Woo, Chapter 7 Trustee in No. 99-04339

Kessner, Duca, Umebayashi, Bain & Matsunaga

220 So. King St., 19^th Flr.

Honolulu, HI 96813

This witness is expected to testify as to the facts of the settlement, including breaches of the Agreement; tax-related issues; conflicts of interests and other issues. As respects the conflicts of interests issue, he is expected to testify regarding his business, financial, and social relationships, if any, with James Duca; Harold C. Johnston; Summit Communications; Sandwich Isles Communications; Robert Kihune; Gilbert Tam; Bank of Hawaii; Herbert Horita, Halekua Development Corp., Ayers Corp., Park Engineering, Larry Mehau, Hawaii Protective Association, AFW, the Harry & Jeanette Weinberg Foundation, Oahu Construction Co., Jeff Stone, Kevin Showe, National Housing Corp., Richard Wong, Henry Peters, Jon Yoshimura, Alan J. Ma, Susan Tius, Art Woolaway, Gray Line Hawaii, Dee Jay Mailer, Alexander & Baldwin, Inc., Hawaiian Insurance & Guaranty Co., C. Brewer & Co., Hawaiian Electric Co., Ronald Libkuman, Benjamin Matsubara, John Mullen & Co., Zurich Financial, and others yet to be named.

Internet References:

www.the-catbird-seat.net/Claims-Branch-Kessner-Duca.htm

NEIL HANNAHS

Land Manager, Kamehameha Schools, in charge of their Kaka`ako development; co-investor in McKenzie Methane.

c/o Kamehameha Schools

567 S. King Street

Honolulu, HI 96813

This witness is expected to testify with regard to the land swap with the State of Hawaii involving KSBE non-revenue producing marsh lands for prime commercial real estate property in the Kaka`ako area, and regarding the John Burns Medical Center project. He is also expected to testify regarding KSBE’s alleged violations of EPA regulations, especially in the Kaka`ako area, including Waterpark Towers, Restaurant Row, and the site of the John Burns Medical Center. Mr. Hannahs is also expected to testify with regard to the land swap with the State of Hawaii, whereby KSBE obtained prime commercial real estate property in Kaka`ako in exchange for commercially valueless marsh lands in the North Shore area. He is also expected to testify regarding his relationships with Nathan Aipa, Colleen Wong, Lyn Anzai, Earl Anzai, Louanne Kam, Ed Tabangay, Stay & Sons, Allen Young, Rocco Sansone, Marsh & McLennan, Paul Cathcart, Elaine Brown, Rodney Park, P&C Insurance Co., Henry Peters, Richard Wong, Jeff Stone, Kevin Showe, National Housing Corporation, Matsuo Takabuki, McKenzie Methane, Kukui Inc., Milton Holt, Guido Giacometti, Susan Tius, Sukamto Sia, Robert Kihune, Colbert Matsumoto, Hawaii Land Use Commission, Maui Planning Commission, Ronald D. Libkuman, Benjamin Matsuura, Milton Holt, Gil Tam, Bank of Hawaii, Yukio Takemoto, Hamilton McCubbin, Gensiro Kawamoto, Carol Asai-Sato, Paul Alston, Alston Hunt Floyd & Ing, CB Richard Ellis, Alexander & Baldwin, Matt Tsukazaki, Robert Katz, Brewer Environmental Industries, C. Brewer & Co., Wendell Brooks, PBS Hawaii, Mary Bitterman, George R. Ariyoshi, Elizabeth Lindsey Buyers, Bill Mills, Robert Alm, First Hawaiian Bank, Hawaiian Electric Company, The Robert & Patricia Switzer Foundation, and others yet to be named.

Internet References:

www.the-catbird-seat.net/IRS-Intermediate-Sanctions.pdf

www.the-catbird-seat.net/Claim-Marsh-Sinnott-1-5-97.htm

www.the-catbird-seat.net/IRS-11-10-97.htm

www.the-catbird-seat.net/KS-IRS-12-2-0.htm

www.the-catbird-seat.net/Claim-Kukui-7-2-2.htm

www.the-catbird-seat.net/KSpens-7-11-2.htm

www.the-catbird-seat.net/Bishop2.htm

www.the-catbird-seat.net/Developers.htm

www.the-catbird-seat.net/GensiroKawamoto.htm

www.the-catbird-seat.net/Kajima.htm

www.the-catbird-seat.net/MaunawiliValley.htm

www.the-catbird-seat.net/Hawaiian-Electric.htm

www.the-catbird-seat.net/AAA-6-21-4.htm

www.the-catbird-seat.net/CV05-00030-Prelim-Docs-List.htm

SAMUEL HATA

Director of Administration, Kamehameha Schools

c/o Kamehameha Schools

567 S. King Street

Honolulu, HI 96813

This witness is expected to testify as to his knowledge of non-bid contracts, bid-rigging and favoritism in the awarding of supply, service and construction contracts by Kamehameha Schools Bishop Estate. In particular, he is expected to testify as to the hiring of Larry Mehau’s security firm Hawaii Protective Association, and contracts awarded to Constructors Hawaii, Inc., and/or Mark Construction, and any knowledge of relationships between Henry Peters, Richard S.H. Wong, and Mark Watase and Craig Watase of Mark Development.

KENNETH B. HIPP, Esq.

Marr, Hipp, Jones & Pepper

Purported attorney for Defendants Henry H. Peters, Richard S.H. Wong, Lokelani Lindsey, Gerard Jervis and Oswald Stender, in Harmon’s RICO lawsuit.

Marr Hipp Jones & Pepper

1001 Bishop Street

Ste. 1550, Pauahi Tower

Honolulu, HI 96813

This witness is expected to testify as to the facts and circumstances of the settlement; provide evidence (Attorney of Record letters), that he was authorized to represent these Defendants in the settlement; reason for no response to Harmon’s letters requesting information and Notices of Claims.

JANET S. HUGHES

Manager, Internal Revenue Service, Recipient of letters from Harmon’s “letter-writing campaign.”

Internal Revenue Service

1244 Speer Blvd., Ste 442

MC4900DEN

Denver, CO 80204-3583

This witness is expected to testify as to the facts regarding Harmon’s testimony relating to the IRS audits of Kamehameha Schools Bishop Estate and P&C Insurance, “arms-length” issues, violations of IRS Section 4958 regulations, and whether Defendant’s reports of tax fraud to the IRS should be considered part of a “letter-writing campaign” in violation of the Settlement Agreement.

ROY F. HUGHES, Esq.

Attorney for Respondent in P&C Insurance Company, Inc., et al, vs. Bobby N. Harmon, Civ. No. 97-0512-02.

1000 Bishop St., Suite 300

Honolulu, HI 96813

This witness is expected to testify regarding his efforts to obtain Attorney of Record letters and investigate possible fraud in the settlement negotiations and in the execution of the Settlement Agreement; his relationship to Island Insurance Co.

PETER A. INDIVERI

President & COO, Inverness Corporation

17-10 Willow St.

Fairlawn, NJ 07410

This witness is expected to testify regarding the facts and circumstances in his lawsuit against Kamehameha Schools/Bishop Estate, and regarding his relationships with any of its Trustees, officers, employees or related companies - including Guido Giacometti, Nathan Aipa, Colleen Wong, Lyn Anzai, and Henry Peters. Mr. Indiveri’s testimony is expected to reveal acts of fraud, racketeering and unfair claims practices by KSBE and its insurance broker, Marsh & McLennan, Inc.

MARYANNE INOUYE

Manager, Benefits Administration,

Kamehameha Schools; Recipient of letters from Harmon’s “letter-writing campaign.”

Kamehameha Schools

1887 Makuakane St.

Honolulu, HI 96817-1887

This witness is expected to testify regarding Harmon’s employment at Kamehameha Schools; his entitlement to Retirement Plan; KSBE’s legal requirements for reporting employee wage income to IRS on Forms W-2 and 1099-R; Harmon’s complaint letters expressing concerns about the safety of Kamehameha Schools Retirement Plan.

GERARD A. JERVIS

Former Kamehameha Schools/Bishop Estate Trustee; Defendant in EQ2048; Real Party in Interest in CV05-00030 - Woo vs. Harmon

c/o Kenneth Hipp, Esq., Marr Hipp Jones...

1001 Bishop Street, Ste 1550

Honolulu, HI 96813

HAROLD C. JOHNSTON

Former executive of GTE Hawaiian Tel; former executive and principal owner of Summit Communications, Inc.

This witness is expected to testify regarding his relationships with Steven Guttman, James Duca, Gilbert Tam, Robert Kihune, Francis Keala, Henry Peters, Randy Funn, Grant Johnston, Chad Johnston, Clayton Hee, Al Hee, Lynne Waters, Tom Okamura, Guido Giacometti, Sukamto Sia, Hawaii Visitors & Convention Bureau, Bank of Hawaii, Sandwich Isles Communications, Inc., Maui Planning Commission, Hawaii Land Use Commission, and other entities yet to be named.

Internet References:

www.the-catbird-seat.net/IRS-Intermediate-Sanctions.pdf

LOUANNE L. KAM, Esq.

Kamehameha Schools attorney; Signatory to Settlement Agreement.

Kamehameha Schools

567 S. King St., Ste 310

Honolulu, HI 96813

This witness is expected to testify as to her actions involving the handling of the settlement negotiations which led to the Settlement Agreement, the tax-related issues, relationships with P&C Insurance, Rodney Park, Marsh & McLennan, Aon Insurance, John Mullen Co.

Internet References:

www.the-catbird-seat.net/Claim-Marsh-Sinnott-1-5-97.htm

www.the-catbird-seat.net/IRS-11-10-97.htm

www.the-catbird-seat.net/EQ2048-AG-Trustees-4-27-0.pdf

www.the-catbird-seat.net/Doc-EQ2048-AG-Witnesses-5-19-0.pdf

www.the-catbird-seat.net/McCubbin-7-26-00.htm

www.the-catbird-seat.net/KS-IRS-12-2-0.htm

ROBERT S. KATZ, Esq.

Atty. For Defendant Torkildson, Katz, Fonseca, Jaffe, Moore & Hetherington in Harmon’s RICO lawsuit; Signatory to Settlement Agreement.

700 Bishop Street

15th Floor

Honolulu, HI 96813

This witness is expected to testify as to the facts and circumstances of the settlement, conflicts-of-interest involving Torkildson, Katz concurrently being a Defendant in Harmon’s RICO lawsuit, attorney for Kamehameha Schools, P&C Insurance, and Torkildson Katz Fonseca Jaffe Moore & Hetherington in related lawsuits. He will also be asked to furnish evidence that Torkildson Katz was properly authorized to act on behalf of Federal and P&C Insurance to negotiate settlement in this case, and to testify regarding tax-related issues.

Internet Reference:

www.the-catbird-seat.net/Claims-Branch-Torkildson-Katz.htm

WILFRED K. KAWANO

Island Insurance Company vice president; Signatory to the Settlement Agreement.

Island Insurance Company

1022 Bethel Street

P.O. Box 1520

Honolulu, HI 96806

This witness is expected to testify regarding the facts and circumstances of Island Insurance Company’s participation in the settlement negotiations which resulted in the Settlement Agreement, and is expected to provide true and complete documentation regarding the amounts of time and monies Island Insurance expended in defending me in P&C INSURANCE COMPANY, INC. AND RICHARD S.H. WONG, OSWALD K. STENDER, LOKELANI LINDSEY, GERARD A. JERVIS AND HENRY H. PETERS, AS TRUSTEES OF THE ESTATE OF BERNICE PAUAHI BISHOP, Plaintiffs, v. BOBBY N. HARMON, Defendant, Civil Case No. 97-0512-02. In particular, this witness is expected to testify regarding the amount of money Island Insurance Company contributed to the Settlement, and an explanation of WHY this company contributed any amount of monies to the settlement as the bankruptcy filing had already relieved me, and my insurance company, of all liabilities in this case.

Internet References:

Exhibit AA - www.the-catbird-seat.net/Doc-Guttman-To-AAA-6-19-4.pdf

Exhibit AB - www.the-catbird-seat.net/AAA-6-21-4.htm

Exhibit AC - www.the-catbird-seat.net/AAA-6-23-4.htm

Exhibit AD - www.the-catbird-seat.net/SettlementChronology.htm

FRANCIS A. KEALA

Interim Trustee of Kamehameha Schools; Signatory to the Settlement Agreement in Case No. 99-04339, U.S. District Court; designated by Arbitrator Judith Neustadter as a “Real Party in Interest” in the instant case.

Kamehameha Schools

567 S. King Street, Suite 310

Honolulu, HI 96813

This witness is expected to testify as to the facts and circumstances of the Settlement in Case No. 99-04339, including Defendant’s alleged breaches of the Agreement through his alleged “letter writing campaign”. He will be asked to verify the names and authenticity of the signatures of the unidentified interim-trustees who signed the Settlement Agreement, and to testify as to the facts and circumstances regarding why they were the Signatories to the Settlement Agreement, and not the former Trustees named in Harmon’s RICO lawsuit. He will also be asked to furnish evidence of his appointment of the attorney purporting to represent him in Case No. 99-04339, and the approval of this attorney by Kamehameha School’s insurance carrier. Mr. Keala will also be asked to describe his relationship to Richard Lyman, former Trustee of Kamehameha Schools, and his knowledge of alleged “favoritism” by former and interim Trustees and Principal Executives in the awarding of Bishop Estate lease agreements, construction contracts, contracts for services and other business and financial agreements - including loans to Trustees, executives and employees of Kamehameha Schools and related companies which were guaranteed by Bishop Estate.

Reference: www.starbulletin.com/2000/11/03/news/story1.html

ROBERT K.U. KIHUNE

Trustee of Kamehameha Schools, and possible Signatory to the Settlement Agreement in Case No. 99-04339, U.S. District Court.

Kamehameha Schools

567 S. King Street, Suite 310

Honolulu, HI 96813

This witness is expected to testify as to the facts and circumstances of the Settlement and the actions taken by Defendant subsequent to entering into the Settlement Agreement, including Defendant’s alleged breaches of the Agreement through his alleged “letter writing campaign”. He will be asked to verify the names and authenticity of the signatures of the unidentified interim-trustees who signed the Settlement Agreement, and to testify as to the facts and circumstances regarding why they were the Signatories to the Settlement Agreement, and not the former trustees who were the Named Defendants in Harmon’s RICO lawsuit. He will also be asked to furnish evidence of the appointment of his attorney in Case No. 99-04339, and the approval of this attorney by Kamehameha School’s insurance carrier. He is expected to testify regarding his personal, business, professional, financial and social relationships, if any, with Gilbert Tam, Sandwich Isles Communications, Al Hee, Clayton Hee, Summit Communications, Steven Guttman, Judith Neustadter Fuqua, Colbert Matsumoto, Island Insurance, Michael Tanoue, Rocco Sansone, Marsh & McLennan, Aon, and others yet to be named.

Internet References:

www.starbulletin.com/2000/11/03/news/story1.html

www.the-catbird-seat.net/Greeneville.htm

www.the-catbird-seat.net/Claims-Branch-Kamehameha.htm

JUDGE BARRY KURREN

Magistrate Judge for the Ninth District; Magistrate Judge in Defendant’s RICO case and for the Settlement Agreement.

This witness is expected to testify regarding the facts and circumstances regarding the Settlement Agreement at issue in this case, and his personal, professional, financial and social relationships with Faye Kurren, William S. Richardson, Judge Kevin Chang, Judge David Ezra, Earl Anzai, Lyn Anzai, Guido Giacometti, Sukamto Sia, Henry Peters, Richard Wong, Hawaii Dental Services (HDS), Gary Rodrigues, Tesoro Hawaii, and others yet to be named.

Internet References:

www.the-catbird-seat.net/AAA-HarmonAnswer-6-14-4.htm

www.the-catbird-seat.net/Claim-Woo-1-21-5.htm

www.the-catbird-seat.net/FiringDobelle.htm

www.the-catbird-seat.net/Paradise.htm

www.the-catbird-seat.net/EQ2048-AG-Trustees-4-27-0.pdf

CHRISTINE LEE

Former Kamehameha Schools employee, Risk & Insurance Dept.

c/o Kamehameha Schools

This witness is expected to testify as to the reporting and handling of Harmon’s various claims against KS and its subsidiaries, and provide basic information regarding these claims, such as: Claim Number, Date Claim Made, Insurance Carrier, Policy Number, Policy Period, Name of Claims Adjuster. If these claims were NOT REPORTED to the insurance carrier or their agent or broker, Christine Lee will be asked why these claims were not reported.

Internet References:

www.the-catbird-seat.net/Claims-Branch-Marsh-McLennan.htm

RONALD D. LIBKUMAN, Esq.

Interim Trustee of Kamehameha Schools, and possible Signatory to the Settlement Agreement in Case No. 99-04339, U.S. District Court.

Kamehameha Schools

567 S. King Street, Suite 310

Honolulu, HI 96813

This witness is expected to testify as to the facts and circumstances of the Settlement and the actions taken by Defendant subsequent to entering into the Settlement Agreement, including Defendant’s alleged breaches of the Agreement through his alleged “letter writing campaign”. He will be asked to verify the names and authenticity of the signatures of the unidentified interim-trustees who signed the Settlement Agreement, and to testify as to the facts and circumstances regarding why they were the Signatories to the Settlement Agreement, and not the former trustees who were the Named Defendants in Harmon’s RICO lawsuit. He will also be asked to furnish evidence of his appointment of his attorney in Case No. 99-04339, and the approval of this attorney by Kamehameha School’s insurance carrier. Mr. Libkuman was also a named Witness for Defendant in the Arbitration proceedings, and will be asked to explain the purpose and content of his private meetings/conferences with Steven Guttman prior to the Arbitration proceedings.

Internet References:

www.the-catbird-seat.net/Claim-IRS-10-10-0.htm

www.the-catbird-seat.net/AAA-Guttman-AttC.pdf

www.the-catbird-seat.net/Claim-Sia-6-25-1.htm

www.the-catbird-seat.net/AttyGen-Anzai-12-5-2.htm

www.starbulletin.com/2000/11/03/news/story1.html

www.the-catbird-seat.net/AAA-9-17-4.htm

www.the-catbird-seat.net/Claim-Sia-9-18-4.htm

www.the-catbird-seat.net/Claims-Branch-Ayabe-Chong.htm

www.the-catbird-seat.net/Claims-Branch-Kamehameha.htm

www.the-catbird-seat.net/Claim-KS-Libkuman-4-13-5.htm

LOKELANI LINDSEY

Former Kamehameha Schools/Bishop Estate Trustee; Defendant in EQ2048; Real Party in Interest in CV05-00030 - Woo vs. Harmon

c/o Kenneth Hipp, Esq., Marr Hipp Jones...

1001 Bishop Street, Ste 1550

Honolulu, HI 96813

PETER J. LOWE

Officer of M&M Insurance Management Services, Inc., former Vice President, P&C Insurance Company

Marsh & McLennan, Inc.

1099 Alakea Street, 22^nd Floor

Honolulu, HI 96813

Tel: 808-531-4211

Fax: 808-521-5892

This witness is expected to testify as to Marsh & McLennan’s initial brokerage contract with P&C, and whether that contract was on a time-and-expense or flat fee basis. He is also expected to testify whether, as an officer of P&C, he was expected to follow directions from the President of P&C, or from Nathan Aipa, Louanne Kam, or other employees of Kamehameha Schools/Bishop Estate regarding the operations and finances of P&C.

ALAN J. MA, Esq.

Gerson & Hieneman, Attorneys at Law

American Savings Bank Twr

1001 Bishop St., Ste 700

Honolulu, HI 96813

Tel: 808-524-4800 - Fax: 808-537-1420

DEE JAY MAILER

CEO, Kamehameha Schools

Kamehameha Schools

567 S. King St., 2^nd Floor

Honolulu, HI 96813

This witness is expected to testify as to the facts and circumstances of Harmon’s “letter-writing campaign,” and her relationships with Wally Chin; Torkildson, Katz, Fonseca, Jaffe, Moore & Hetherington; Colleen Wong; Louanne Kam; Maryanne Inouye; P&C Insurance; Marr, Hipp, Jones & Pepper; Jeffrey Sia; Susan Tius; Art Woolaway; Gray Line Hawaii; Patty Woolaway; C. Brewer & Co.; Hawaiian Insurance & Guaranty Co.; Alexander & Baldwin; Steven Guttman, Esq.; Alan J. Ma, Esq.; Marsh & McLennan; Aon; Chubb Group; AIG; Maui County Council; Maui Planning and Land Use Committee; Hawaii Land Use Commission, and others yet to be named. Ms. Mailer is also expected to testify as to her role in the review and processing of Harmon’s various liability claims against the interim and present trustees, CEO Hamilton McCubbin, herself, various for-profit subsidiaries, their directors, officers, and employees, and sub-contractors for these entities, including Marsh & McLennan, Inc., Aon, and other insurance agents, brokers and companies.

CLYDE MARK

Former President of P&C Insurance Company, Inc.

Kamehameha Schools

567 S. King Street, Suite 310

Honolulu, HI 96813

This witness is expected to testify as to the fact of whether or not he is a licensed Claims Adjuster for P&C Insurance Co., Inc.; provide a signed copy of P&C’s Indemnity Agreement that Harmon signed when named as P&C’s president; and testify if he was a paid officer of P&C, as well as a paid employee of Kamehameha Schools; and whether or not he submitted Harmon’s tender of defense in this case to P&C’s Professional Liability Carrier and, if not, why not. Mr. Mark will be asked to provide the name, policy number, policy period, date claim made, claim number and name of the Claims Adjuster for P&C’s Professional Liability Carrier in the RICO lawsuit, and why P&C did not respond to Harmon’s various Notice of Claim letters.

Internet References:

www.the-catbird-seat.net/EQ2048-AG-Trustees-4-27-0.pdf

www.the-catbird-seat.net/Claims-Branch-Kamehameha.htm

BENJAMIN M. MATSUBARA, ESQ.

Kamehameha Schools’ Court-appointed Master

888 Mililani St., 8^th Floor

Honolulu, HI 96813-2918

This witness is expected to testify regarding the following entries in Steven Guttman’s Declaration in Support of Claimant’s Request for Fees and Costs, received on September 2, 2004:

01/26/04

WI RVW BH LTR TO AON INSURANCE

SG TC FROM BEN MATSUBARA RE WITNESS TESTIMONY

SG REVIEW BNH LTRS TO AON

Benjamin M. Matsubara, Esq. had many connections with the arbitration case:

> Benjamin Matsubara is the court-appointed Master for Kamehameha Schools/Bishop Estate;

> Benjamin Matsubara was the recipient of several of the letters in my “letter-writing campaign” - which was an issue in the arbitration;

> Benjamin Matsubara has been the attorney for Alexander & Baldwin, Ltd. (A&B) in major land use cases on Maui, and other areas, representing them before the Hawaii Land Use Commission (LUC) and Maui County Planning Commission, for which Arbitrator Judith Neustadter Fuqua, is a hearing officer.

> Benjamin Matsubara was one of Respondent’s named witnesses at the time of this phone conversation.

Since Steven Guttman’s time sheets do not provide details about what was discussed during this conversation, Mr. Matsubara will be expected to describe the purpose and content of this telephone contact. Regardless of the purpose, however, I maintain that the fact that Benjamin Matsubara directly contacted Steven Guttman to discuss his witness testimony was an improper breach of ethics and fair dealing.

Internet References:

www.the-catbird-seat.net/Developers.htm

www.the-catbird-seat.net/Alexander-Baldwin.htm

www.the-catbird-seat.net/AAA-Guttman-AttB.pdf

COLBERT MATSUMOTO

Master, Kamehameha Schools; former attorney and current President, Island Holdings Inc.; Director, City Bank Company, CB Bancshares Inc., National Mortgage & Finance Co. Ltd., Oahu Publications Inc., Hawaii Employees' Retirement System, and Island Insurance Company Ltd., of which he is chairman; member of Department of Land and Natural Resources, State of Hawaii; recipient of letters in Respondent’s alleged “letter-writing campaign” which is at issue in the instant arbitration.

Amfac Tower, Suite 2000
700 Bishop Street
Honolulu, Hawaii 96813

This witness is expected to testify as to the facts regarding his relationships to Respondent Bobby Harmon; Kamehameha Schools; P&C Insurance Company; Island Insurance Company; Gilbert Tam; Roy Hughes, Esq.; County of Maui; Maui Planning Commission, Hawaii Land Use Commission, and others to be determined.

Internet References:

www.the-catbird-seat.net/Claims-Branch-Island.htm

www.the-catbird-seat.net/Claims-Branch-Master.htm

JOE MCCOLLOUGH

Vice President for General Liability Claims, United Educators Insurance Co.

Two Wisconsin Circle, Suite 400

Chevy Chase, MD 20815

This witness is expected to testify regarding the failure of Nathan Aipa, Colleen Wong, Lyn Anzai, Louanne Kam and other employees of Kamehameha Schools/Bishop Estate to report liability claims on a timely basis, and the failure of these individuals to provide information to, and cooperate with, United Educators’ claims adjusters in the adjustment of claims - including the failure of KSBE to follow UE’s Guidelines pertaining to the engagement of outside attorneys. Also, Joe McCullough is expected to testify regarding losses to the beneficiaries of Kamehameha Schools of hundreds of thousands of dollars in denied claims payments due to these failures to follow the Terms and Conditions of their insurance policy, including the following claims: McKenzie Methane, William Rosehill, and Kona Enterprises. His testimony also is expected to reveal acts of fraud, tax fraud, overcharges, kick-backs, unfair claims practices, and other wrongful acts by KSBE’s insurance broker, Marsh & McLennan.

Internet references:

www.the-catbird-seat.net/EQ2048-AG-Trustees-4-27-0.pdf

www.the-catbird-seat.net/McCubbin.htm

HAMILTON MCCUBBIN

Former CEO, Kamehameha Schools.

Kamehameha Schools

567 S. King Street, Suite 310

Honolulu, HI 96813

This witness is expected to testify regarding the facts and circumstances of the Settlement Agreement, and his relationships with Nathan Aipa, Colleen Wong, Louanne Kam, Rodney Park, Clyde Mark, Christine Lee, Rocco Sansone, Marsh & McLennan, Inc., Aon Risk Management Services, Judge Kevin Chang, Colbert Matsumoto, Benjamin Matsubara, Miller & Chevalier, Morgan Lewis & Bockius, Robert Katz, Matt Tsukazaki, Torkildson Katz Fonseca Jaffe Moore & Hetherington, Susan Tius, Guido Giacometti, Yukio Takemoto, Evan Dobelle, Gilbert Tam, Robert Kihune, Maui Planning Commission, and others yet to be named.

Internet References:

www.the-catbird-seat.net/McCubbin-MorganLewis.htm

www.the-catbird-seat.net/Bishop3.htm

www.the-catbird-seat.net/ConnecticutConnection.htm

HARBEN MICHAEL MCKENZIE

Previous owner of McKenzie Methane, Inc.; sued Bishop Estate regarding the purchase; named as witness in EQ2048.

2222 Country Club

Sugar Land, TX 77478

This witness is expected to testify regarding the facts and circumstances regarding the purchase of his company, McKenzie Methane, Inc., by Kamehameha Schools/Bishop Estate and the following individuals: Henry Peters (trustee); William Richardson (former trustee and subsequent consultant, Sec./Treasurer of P&C); Myron Thompson (former trustee); Matsuo Takabuki (former trustee and subsequent consultant); Dave Thomas (owner of Wendy’s restaurants and co-investor with KSBE on several other projects); William E. Simon (former U.S. Treasury Secretary, and co-investor with KSBE on several other projects, including HonFed Savings & Loan, Sino Finance, Xiamen Bank (China), and SoCal Holdings); Wayne Rogers (the “Mash” actor, who later brought suit against KSBE for the Kona Enterprises deal); Bruce Nelson (treasurer of the Rockefeller Group); Raymond Pettit (CFO of the Rockefeller Group); Frederick “Ted” Field (three Field employees also invested. . .Field was the estate’s partner in the corporate takeover of European conglomerate DRG, Inc. He later brought suit against the estate in a co-investment deal involving The Pantry); Mark McConaghy (Bishop Estate’s principal tax lawyer and lobbyist. McConaghy, who works for the Price Waterhouse accounting firm’s national headquarters in Washington, D.C., was a finalist on last year’s state Supreme Court list of nominees to fill the latest vacancy on the estate board of trustees); Michael Chun (President of Kamehameha Schools); Gilbert Tam (at the time Director of Administration, KSBE, and an officer of Bank of Hawaii and director, P&C); Guido Giacommetti (then Director of Asset Management, KSBE); Anthony Sereno (deceased, then Board of Directors, Royal Hawaiian Shopping Center, Inc.); Neil Hannahs (head of the estate’s Kakaako development project); Charles Maeda (head of Information Services Division, KSBE); Richard Wong (president of RHSC and Pauahi Holdings Corp.); Wallace Tirrell (then president of Kamehameha Investment Corp.); Gilbert Ishikawa (KSBE tax manager); Ed Hendrickson (KSBE Financial Assets Division); Rodney Park (then KSBE Controller; currently Director, Administration Group, and President, P&C); Wally Chin (then Deputy Controller; currently Controller, KSBE); Donald K. H. Pang (father of KSBE employee, Leeanne Crabbe).

Internet References:

www.starbulletin.com/97/10/20/news/story3.html

www.the-catbird-seat.net/Claim-Marsh-Sinnott-1-5-97.htm

www.the-catbird-seat.net/FBI-9-17-98.htm

www.the-catbird-seat.net/AlohaHarken.htm

www.the-catbird-seat.net/SimonSays.htm

www.the-catbird-seat.net/PriceWaterhouse.htm

www.the-catbird-seat.net/SettlementChronology.htm

www.the-catbird-seat.net/McCubbin-7-26-00.htm

www.the-catbird-seat.net/IRS.htm

www.the-catbird-seat.net/AAA-JUSTICE-10-31-0.htm

www.the-catbird-seat.net/AAA-SEC-1-5-1.htm

www.the-catbird-seat.net/Greeneville.htm

www.the-catbird-seat.net/AAA-Guttman-5-29-1.htm

www.the-catbird-seat.net/Kajima.htm

www.the-catbird-seat.net/Claim-Island-9-27-4.htm

www.the-catbird-seat.net/Claim-Woo-10-1-4.htm

www.the-catbird-seat.net/Claim-IRS-3-28-5.htm

TERRY MULLEN

CEO/President, John Mullen & Co., Party to the Settlement Agreement.

John Mullen & Company

P.O. Box 2096

Honolulu, HI 96803

As John Mullen & Company was a named Defendant in Harmon’s RICO lawsuit, this witness is expected to testify as to the facts and circumstances leading to the Agreement, as related to his role as the independent claims adjuster for P&C Insurance Company, Inc., and the tax-related issue of the treatment of the Settlement proceeds as wages. As a named Witness for Defendant in the Arbitration proceedings, he will be asked to explain the purpose and content of his private meetings/conferences with Steven Guttman prior to the Arbitration, and to explain his relationship with Rene Stone and Zurich Financial Services, and why John Mullen & Co. did not respond to his Notice of Claim letter dated Oct 8, 2004, or subsequent follow-up claims notices.

Internet References:

www.the-catbird-seat.net/EQ2048-AG-Trustees-4-27-0.pdf

www.the-catbird-seat.net/Claims-Branch-Mullen.htm

www.the-catbird-seat.net/Zurich.htm

RODNEY PARK

President, P&C Insurance Company, Inc.; Director, Administration Group, Kamehameha Schools; Signatory to Settlement Agreement; recipient of letters in Harmon’s alleged “letter-writing campaign.”

c/o Jeffrey H.K. Sia, Esq., Ayabe Chong Nishimoto Sia & Nakamura

Pauahi Tower, Ste. 2500

Honolulu, HI 96713,

and/or

c/o Matt Tsukazaki, Esq.,

Torkildson, Katz, Fonseca, Jaffe, Moore & Hetherington

700 Bishop Street, 15th Floor

Honolulu, HI 96813

This witness is expected to testify as to the facts of the settlement and his relationships with Kamehameha Schools, P&C Insurance Co., Gilbert Tam, William S. Richardson, Nathan Aipa, Colleen Wong, Louanne Kam, Christine Lee, Dan Jones, Lyn Anzai, Guido Giacometti, Susan Tius, Sukamto Sia, Robert Katz, Esq, Matt Tsukazaki, PricewaterhouseCoopers, Mark McConaghy, McKenzie Methane, Federal Insurance Co. (Chubb Group), Marsh & McLennan, Rocco Sansone, Peter Lowe, John Mullen Company, Yukio Takemoto, Milton Holt, Calvin Say and others yet to be named. With respect to insurance coverages provided to KSBE and all related companies, Mr. Park is expected to provide for EACH claim that Harmon has made against KSBE and related entities, the following information: the name of the insurance carrier, their agent or broker, their address, policy number, policy period, claim number, and date claim made. He is also expected to testify whether or not he is a licensed Claims Adjuster, and expected to provide the name and address of the licensed Claims Adjuster who was responsible for adjusting EACH of Harmon’s claims, including his Wrongful Termination and RICO lawsuits. Mr. Park also expected to testify regarding alleged tax fraud, insurance fraud, bribes, kick-backs, bid-rigging, unfair claims practices and other illegal acts involving Marsh & McLennan, Federal Insurance Company (Chubb Group), Aon, and other insurance carriers and agents yet to be named, and he is expected to testify regarding alleged violations of IRS regulations, illegal campaign contributions, obstruction of justice, and other wrongful acts by former, interim and current trustees, directors, officers, employees and independent contractors for Kamehameha Schools, its subsidiaries and related companies, including P&C Insurance Company, Inc.

Internet References:

www.the-catbird-seat.net/IRS-Intermediate-Sanctions.pdf

www.the-catbird-seat.net/EQ2048-AG-Trustees-4-27-0.pdf

www.the-catbird-seat.net/Claims-Branch-Kamehameha.htm

www.the-catbird-seat.net/IRS-Intermediate-Sanctions.pdf

HENRY H. PETERS

Former Kamehameha Schools/Bishop Estate Trustee; Chairman of the Board, P&C Insurance Company; Defendant in EQ2048; Real Party in Interest in CV05-00030 - Woo vs. Harmon

c/o Kenneth Hipp, Esq., Marr Hipp Jones...

1001 Bishop Street, Ste 1550

Honolulu, HI 96813

This witness is expected to provide evidence that Kenneth Hipp, Esq. was his appointed attorney in Harmon’s RICO lawsuit, and that Mr. Hipp’s appointment was formally approved, in writing, by Federal Insurance Company. This witness also is expected to describe his authorities as a former KSBE Trustee and as Chairman of the Board of P&C Insurance Company, as it relates to “arms-length” guidelines and IRS Section 4958 regulations.

Internet References:

www.the-catbird-seat.net/EQ2048-AG-Trustees-4-27-0.pdf

www.the-catbird-seat/net/Methane.htm

ROBERT P. RICHARDS, ESQ.

Special Master appointed by Judge Kevin Chang to investigate Bishop Estate in EQ2048.

Richards & Luke

2700 Pauahi Tower

Honolulu, HI 96813

Fax: 808-536-5117

This witness is expected to testify regarding his appointment by Judge Kevin Chang of Hawaii’s 1^st Circuit Court as a master in charge of reviewing spending records and other filings by the five Bishop Estate trustees in EQ2048. In particular, Mr. Richards will be asked to comment on his finding that, “The conclusion of this master (is) that no stone would be left unturned by the trustees in attempting to silence their critics. ... There was a constant effort made, nearly always unsuccessful, to take steps to silence of discredit what was perceived to be the ‘opposition,’ whether that was an employee, a reporter, the attorney general, a judge or a master.” In his report, Richards also said that Bishop Estate spent considerable trust funds researching the free-speech limitations of senior U.S. District Judge Samuel King, an outspoken critic of the trust, and looked into possible remedies against Bobby Harmon, the former head of the estate’s insurance subsidiary, in an apparent attempt to silence criticism. Robert Richards also is expected to testify regarding the hiring of outside law firms by Nathan Aipa in for “inappropriate legal work” in connection with EQ2048, and with regard to the IRS audits of the Estate. In particular, Mr. Richards is expected to testify regarding the work of law firms of Ashford & Wriston; Cades Shutte Fleming & Wright; McCorriston Miho Miller & Mukai; Miller & Chevalier, and Morgan Lewis & Bockius.

Internet references:

www.starbulletin.com/97/10/20/news/story3.html

www.starbulletin.com/2000/05/18/news/story1.html

www.starbulletin.com/2000/05/20/news/story1.html

www.starbulletin.com/2000/10/04/editorial/letters.html

www.the-catbird-seat.net/McCubbin-7-26-00.htm

www.the-catbird-seat.net/McCubbin-MorganLewis.htm

www.the-catbird-seat.net/Claims-Branch-Cades-Schutte.htm

www.the-catbird-seat.net/EQ2048-AG-Trustees-4-27-0.pdf

www.the-catbird-seat.net/EQ2048-Richards-Report-pp1-26.pdf

www.the-catbird-seat.net/EQ2048-Richards-Report-pp26-49.pdf

www.the-catbird-seat.net/EQ2048-Richards-Report-pp50-75.pdf

www.the-catbird-seat.net/EQ2048-Richards-Report-Ex-2.pdf

www.the-catbird-seat.net/EQ2048-Richards-Report-Ex-2b.pdf

WILLIAM S. RICHARDSON

Former Chief Justice of the Hawaii Supreme Court; former Bishop Estate Trustee; Sec./Treas., P&C Insurance Co., Inc.; Co-investor in McKenzie Methane; Party to the Settlement Agreement in Case No. 99-04339, U.S. Bankruptcy Court for the District of Hawaii; Real Party in Interest in CV05-00030-DAE-KSC - Woo vs. Harmon.

c/o Jeffrey H.K. Sia, Esq., Ayabe Chong Nishimoto Sia & Nakamura

Pauahi Tower, Ste. 2500

Honolulu, HI 96713,

and/or

c/o Matt Tsukazaki, Esq.,

Torkildson, Katz, Fonseca, Jaffe, Moore & Hetherington

700 Bishop Street, 15th Floor

Honolulu, HI 96813

This witness is expected to testify as to the facts and circumstances of the settlement, including possible fraud in the execution of the Settlement Agreement; his personal, family, business, and social relationships with Respondent Bobby Harmon; Trustees of Kamehameha Schools/Bishop Estate; P&C Insurance Co.; Gilbert Tam; Henry Peters; Dan Jones; Nathan Aipa; Colleen Wong; Louanne Kam; Lyn Anzai; Mitch Gilbert; Guido Giacometti; Susan Tius; Sukamto Sia; Eric Martinson; Bruce Nakaoka; Dennis Fern; Rocco Sansone; Peter Lowe; Marsh & McLennan; Matt Tsukazaki, Esq.; Robert Katz, Esq.; Jeffrey H.K. Sia; Mark McConaghy; PricewaterhouseCoopers; John Mullen Company, Inc.; Federal Insurance Company; J.P. Schmidt, Esq.; Bank of Hawaii; Colbert Matsumoto, Esq; Benjamin Matsubara, Esq; James Duffy, Esq.; Judge Kevin Chang; Judge David Ezra; Judge Barry Kurren; Judge Lloyd King; Judge Robert Ferris; Attorney General Robert Bennett; Earl Anzai, Esq; William K. Richardson, Esq.; HMS Management Partners; University Connections; Hawaii Business Entrepreneur Acceleration Mentors (HiBEAM); Kona Bay Marine Resources; Pacific Information Exchange; Pacific Direct Connect; Hawaii Biotech, Inc.; Digital Island, Inc., The University of Hawaii Foundation; Art Woolaway, and other entities yet to be named. This witness is also expected to testify regarding his investment in McKenzie Methane, and any loans from Bank of Hawaii or other financial institutions which may have been guaranteed by Kamehameha Schools/Bishop Estate. Mr. Richardson is also expected to testify regarding payment of expenses for he, and a friend, to attend the 1996 Hawaii Captive Insurance Forum at the Mauna Lani Hotel, Kohala, Hawaii, arranged by Peter Lowe. He is also expected to testify regarding the reason why, in his position as Secretary/Treasurer of P&C Insurance Company, he approved P&C’s 1996 financial statements filed with the Hawaii Department of Insurance, when the president of the company had previously declined to approve the financials due to questionable expenses, investments and unearned premium and loss reserves.

Internet References:

www.the-catbird-seat.net/IRS-Intermediate-Sanctions.pdf

www.the-catbird-seat.net/EQ2048-AG-Trustees-4-27-0.pdf

WILLIAM ROSEHILL

Former Kamehameha Schools land manager.

Kamehameha Schools

c/o Matt A. Tsukazaki, Esq.

Torkildson Katz Fonseca Jaffe Moore & Hetherington

AmFac Tower, 700 Bishop Street, Floor 15

Honolulu, HI 96813

This witness is expected to testify regarding alleged kickbacks from lessees to KSBE managers and employees, including the events and circumstances regarding the “sandlewood investigation” of Umikoa Ranch which led to the trustees approval of disciplinary action against Mr. Rosehill, William Stayton, Guido Giacometti, Sydney Keliipuleole and Wallace Terrell. This witness is also expected to testify regarding Bishop Estate’s relationship with Senator David Matsuura.

Internet References:

www.the-catbird-seat.net/SINNOTT-1-5-97.htm

www.the-catbird-seat.net/IRS-11-10-97.htm

www.the-catbird-seat.net/McCubbin.htm

www.the-catbird-seat.net/Harmon-Trustees.htm

www.the-catbird-seat.net/AAA-HarmonAnswer-6-14-4.htm

www.the-catbird-seat.net/Claim-Woo-10-1-4.htm

www.the-catbird-seat.net/CV05-00030-Prelim-Docs-List.htm

ROCCO SANSONE,

Officer, Marsh & McLennan Companies, former insurance broker for Kamehameha Schools and P&C Insurance Company.

Marsh & McLennan

745 Fort Street, Suite 1100,

Honolulu, HI 96813

This witness is expected to testify as to the facts and circumstances of the settlement; his relationships with Respondent Bobby Harmon; Kamehameha Schools; P&C Insurance Co; Rodney Park; Marsh & McLennan, Inc.; Wally Chin; Peter Lowe; Nathan Aipa; Louanne Kam; Colleen Wong; William S. Richardson; Henry Peters; Gilbert Tam; Matt Tsukazaki; Richard Wong; Lokelani Lindsey; Jeff Stone; Kevin Showe; Ko Olina Partners; Seibu (Prince Hotels); Sukamto Sia; Bank of Honolulu; HonFed Savings & Loan; Investor’s Equity; Wayne Metcalf, Esq.; Judge Rey Graulty; J.P. Schmidt; Colbert Matsumoto; Island Insurance Co.; Hawaiian Insurance & Guaranty Co.; C. Brewer & Co.; Ron Poepoe; Dee Jay Mailer; Patty Woolaway; Art Woolaway; “Bud” McNeil; HonFed Savings & Loan; Investors Equity, and others. He is expected to testify regarding possible bribes, bid-rigging, excessive charges, fraud, tax fraud, non-reporting of claims to KSBE and P&C insurance carriers, unfair claims practices, collusion with Louanne Kam, Christine Lee, Nathan Aipa and others, in falsifying KSBE’s insurance renewal applications, which resulted in denials of coverage from Federal Insurance Co., XL Insurance, and American Re in EQ2048, which resulted in losses to Kamehameha Schools in excess of $50 million, as well as in the settlement of the underlying Wrongful Termination and RICO lawsuits which resulted in the Settlement Agreement which was the subject of the Plaintiff’s Demand for Arbitration. Mr. Sansone also is expected to testify regarding Marsh & McLennan’s written contract with P&C Insurance Company to provide services on a “time and expense” basis, and to explain why Marsh & McLennan violated this written contract by submitting billings on a “flat fee” basis. This witness also is expected to testify if any of M&M’s bids were “rigged” or falsified in collaboration with Federal Insurance Company, American Re, AIG, Aon or others, and whether Henry Peters, Richard Wong, or other trustees, officers, directors, employees or independent contractors of KSBE or any of its subsidiaries received any financial considerations or benefits from any companies in which Marsh & McLennan and KSBE had common financial interests (i.e., Mid-Ocean Reinsurance, Centre Reinsurance, Ace Ltd., Zurich Financial, Goldman Sachs, etc.), including bribes, kick-backs, quid pro quo, loan guarantees or other financial incentives.

Internet References:

www.the-catbird-seat.net/IRS-Intermediate-Sanctions.pdf

www.the-catbird-seat.net/EQ2048-AG-Trustees-4-27-0.pdf

www.the-catbird-seat.net/Claims-Branch-Marsh-McLennan.htm

www.the-catbird-seat.net/BH-CHRON-97-99.htm

www.the-catbird-seat.net/EQ2048-AG-Trustees-4-27-0.pdf

www.the-catbird-seat.net/Doc-EQ2048-AG-Witnesses-5-19-0.pdf

J. P. SCHMIDT, Esq.

Appointed by Gov. Linda Lingle as Hawaii Insurance Commissioner, January, 2003; Maui County deputy corporation counsel, 1991-1995; Maui County corporation counsel, 1995-1999.

This witness is expected to testify regarding the reasons Harmon’s various complaints, beginning in 1996, against Marsh & McLennan, Federal Insurance Company (Chubb Group), Aon Insurance, P&C Insurance Company, XL Insurance Company (Bermuda), Island Insurance Company, St. Paul Travelers Insurance, and others have not been acted upon by the Hawaii Insurance Division. In support of his testimony, Mr. Schmidt is expected to produce copies of all correspondence from Harmon and copies of all correspondence with the parties named in Harmon’s complaints, internal notes, memorandums, emails, meeting minutes, telephone messages and other documents relating to his department’s discussions, investigations, decisions and actions taken regarding these complaints. Mr. Schmidt also is expected to describe his past and present business, professional, family, and social relationships, if any, between himself and/or his law firm, and Judith Neustadter Fuqua, the Maui County Planning Commission, Linda Lingle, Robert Awana, First Insurance Company, Kamehameha Schools/Bishop Estate, Earl Anzai, Lyn Anzai, Colbert Matsumoto, Island Insurance Co., Seibu Group, Everett Dowling, Calvin Say, Sports Shinko, Robert Katz, Esq., C. Brewer & Co., Brewer Environmental Industry, Inc., Marsh & McLennan, Maui Land & Pineapple, Jeffrey Stone, Suntory, Ltd., Mitsui & Co., Apollo Advisors, Blackstone Group, Trinity Investment, Robert F. Clarke, Edwina Clarke, Hawaiian Electric Industries, Allen Doane, Alexander & Baldwin, Matson Navigation, Constance Lau, American Savings & Loan, Jeffrey N. Watanabe, Bert A. Kobayashi, Michael J. Chun, Walter Dods, Jr., Madelyn D/Enbeau, Hale O Kaula Church, Royal & SunAlliance Insurance Co., D.R. Horton Company, Maui Lani Partners, Bill Mills, Makena Resort, and others yet to be named.

Internet References:

www.the-catbird-seat.net/EQ2048-AG-Trustees-4-27-0.pdf

www.the-catbird-seat.net/Claims-Branch-Commissioners.htm

www.the-catbird-seat.net/Claims-Branch-Marsh-McLennan.htm

www.the-catbird-seat.net/AlliedWorldAssurance.htm

www.the-catbird-seat.net/Aon.htm

www.the-catbird-seat.net/AIG.htm

www.the-catbird-seat.net/PriceWaterhouse.htm

www.the-catbird-seat.net/Claims-Branch-Aon.htm

www.the-catbird-seat.net/Claims-Branch-Island.htm

www.the-catbird-seat.net/Royal-SunAlliance.htm

www.the-catbird-seat.net/Travelers-St-Paul.htm

www.the-catbird-seat.net/Claims-Branch-St-Paul-Travelers.htm

www.the-catbird-seat.net/XL.htm

www.the-catbird-seat.net/Claims-Branch-XL.htm

www.the-catbird-seat.net/Zurich.htm

www.the-catbird-seat.net/Claims-Branch-Zurich.htm

DOROTHY SELLERS, Esq.

Deputy Attorney General, State of Hawaii

425 Queen St., Rm 317

Honolulu, HI 96813

This witness is expected to testify regarding the insurance coverages for the former Bishop Estate Trustees, and the non-cooperation of Louanne Kam, Nathan Aipa and the interim trustees, during the investigation and legal proceedings for EQ2048. She is also expected to testify regarding Harmon’s evidence and testimony in those proceedings.

Internet References:

www.the-catbird-seat.net/EQ2048-AG-Trustees-4-27-0.pdf

www.the-catbird-seat.net/Claim-Woo-10-1-4.htm)

JEFFREY H.K. SIA, Esq.

Ayabe, Chong, Nishimoto, Sia & Nakamura

Purported attorney for Defendant P&C Insurance Company in Harmon’s RICO lawsuit.

Ayabe Chong Nishimoto Sia & Nakamura

1001 Bishop Street

Ste. 2500, Pauahi Tower

Honolulu, HI 96813

Internet Reference:

www.the-catbird-seat.net/Claims-Branch-Ayabe-Chong.htm

OSWALD K. STENDER

Former Kamehameha Schools/Bishop Estate Trustee; Defendant in EQ2048; Real Party in Interest in CV05-00030 - Woo vs. Harmon

c/o Kenneth Hipp, Esq., Marr Hipp Jones...

1001 Bishop Street, Ste 1550

Honolulu, HI 96813

YUKIO TAKEMOTO

Principle Executive of the Budget and Review Group, Kamehameha Schools; also, a Named Witness in EQ2048.

Kamehameha Schools

567 S. King Street

Honolulu, HI 96813

This witness is expected to testify regarding alleged bribes, kickbacks, conflicts of interests, violations of IRS regulations, illegal campaign contributions, obstruction of justice, “arms-length” issues, and other wrongful acts by former, interim and current trustees, directors, officers, employees and independent contractors for Kamehameha Schools, its subsidiaries and related companies.

Internet References:

www.the-catbird-seat.net/Paradise.htm

GILBERT TAM -

Former Director of Administration, Kamehameha Schools; Director, P&C Insurance Co.

Address To Be Determined

This witness is expected to testify as to the facts and circumstances of the settlement; his relationships with Steven Guttman; Mary Lou Woo; Bank of Hawaii; Todd Hoch; Margo Corliss; Bank of Hawaii, Palau Branch; Respondent Bobby Harmon; Kamehameha Schools; P&C Insurance Co; Sandwich Isles Communications; Robert K.U. Kihune; Al Hee; Clayton Hee; Summit Communications; Harold Johnson; Grant Johnson; Frank Carlucci; Carlyle Group; MacArthur Foundation; Adele Smith Simmons; WCI Communities; Rodney Park; Matsuo Takabuki; Marsh & McLennan, Inc.; Wally Chin; Rocco Sansone; Peter Lowe; Nathan Aipa; Louanne Kam; Colleen Wong; Lyn Anzai; Earl Anzai; Guido Giacometti; Sukamto Sia; William Rosehill; Sandie Wicklein; Sam Hata; Yukio Takemoto; Dennis Fern; Andrea Oshiro; Ramona Hinck; Doyal Davis; Maryanne Inouye; Bruce Nakaoka; Eric Martinson; Aaron Au; Daniel Jones; Mitch Gilbert; Sydney Keliipuleole; Charles Maeda; Neil Hannahs; Michael Chun; Ed Tabangay; Mark McConaghy; PricewaterhouseCoopers; Allen Young; Glenn Hara; Cary Okawa; Dennis Tsuhaka; Carl Kobayashi; William S. Richardson; Henry Peters; Matt Tsukazaki; Richard Wong; Paul Cathcart; Bank of Honolulu; HonFed Savings & Loan; Investor’s Equity; Kona Enterprises; Wayne Metcalf, Esq.; Judge Rey Graulty; Peter Trask; David Trask; James Duffy; Benjamin Matsubara; Maui County Planning Department; Linda Lingle; Colbert Matsumoto; Island Insurance Co.; and others. He is expected to testify regarding possible bribes, bid-rigging, excessive charges, fraud, tax fraud, non-reporting of claims to KSBE’s and P&C’s insurance carriers, and unfair claims practices. Mr. Tam is expected to testify regarding KSBE’s alleged practice of requiring its Notaries Public to notarize signatures of the Trustees and others without witnessing the signatures or having the signatory initial the Notary Log. He is expected to testify regarding KSBE’s alleged practice of “influencing” the “independent” appraiser property valuations. Gilbert Tam is expected to testify whether he, Henry Peters, Richard Wong, or other trustees, officers, directors, employees or independent contractors of KSBE or any of its subsidiaries received any financial considerations or benefits from any companies in which Marsh & McLennan and KSBE had common financial interests (i.e., Mid-Ocean Reinsurance, Centre Reinsurance, Ace Ltd., Zurich Financial, Goldman Sachs, etc.), including bribes, kick-backs, quid pro quo, loan guarantees from Bank of Hawaii, or any other type of financial incentives. Mr. Tam is expected to testify regarding his personal investments, or investments by any family members, in McKenzie Methane. As a director of P&C Insurance Company, Mr. Tam is expected to testify regarding the circumstances of Harmon’s termination as President of that company, including the names of all persons making recommendations to the board of directors that Harmon be terminated, the reasons given for the termination, and whether or not he voted for, or against, the termination.

References:

www.the-catbird-seat.net/IRS-Intermediate-Sanctions.pdf

www.the-catbird-seat.net/ConnecticutConnection.htm

www.the-catbird-seat.net/EQ2048-AG-Trustees-4-27-0.pdf

www.the-catbird-seat.net/Doc-EQ2048-AG-Witnesses-5-19-0.pdf

www.the-catbird-seat.net/Claim-Tamm-9-28-4.htm

BRADLEY R. TAMM, Esq.

Former Attorney for Bobby Harmon in the instant Bankruptcy case.

828 Fort Street Mall, Ste 330

Honolulu, HI 96183

This witness is expected to testify as to the circumstances regarding the Settlement, Release and Indemnification Agreement which was approved by the Bankruptcy Court on March 24, 2000; possible fraud in the Settlement negotiations; tax-related issues; Harmon’s “letter-writing campaign”.

Internet References:

www.the-catbird-seat.net/Claims-Branch-Dunn-Tamm.htm

MICHAEL N. TANOUE

Attorney for Island Insurance Co. assigned to matters regarding CV05-00030.

The Pacific Law Group

700 Bishop Street Tower, Suite 2000

Honolulu, HI 96813

Fax: 808-523-7885

This witness is expected to testify as to conflicts of interests, obstruction of justice, and unfair claims practices, in that Michael Tanoue was the attorney appointed by Probate Judge Kevin Chang as Special Master to review the insurance coverages of Kamehameha Schools Bishop Estate in the state’s suit for removal of the former trustees, while also being assigned by Island Insurance to handle Harmon’s case.

Internet References:

www.the-catbird-seat.net/Bishop4.htm

www.the-catbird-seat.net/Claim-Island-9-27-4.htm

www.the-catbird-seat.net/Claim-Island-2-4-5.htm

www.the-catbird-seat.net/Claim-Island-3-7-5.htm

www.the-catbird-seat.net/Complaint-HID-Island-3-15-5.htm

www.starbulletin.com/2000/11/03/news/story1.html

www.the-catbird-seat.net/Claims-Branch-Island.htm

SUSAN TIUS, Esq.

Attorney for Kamehameha Schools in Ch. 7 Bankruptcy No. 99-04339

Rush Moore Craven Sutton Morry & Beh

Hawaii Tower, 20^th Floor

745 Fort Street

Honolulu, HI 96813

This witness is expected to testify as to the facts and circumstances of the settlement, including possible fraud; tax related issues; her relationships with Guido Giacometti, Mary Lou Woo, Steven Guttman, Sterling & Tucker; Aloha Tower LP, Sanford Murata, Mitsui Trust & Banking, Paul Alston, Scott McCormack, Jon Miho, Trinity Investment, others.

Internet Reference:

www.the-catbird-seat.net/Claims-Branch-Rush-Moore.htm

www.the-catbird-seat.net/YAKUZA.htm

DENNIS TSUHAKO, CPA

Employee of PricewaterhouseCoopers, LLP. (Formerly Coopers & Lybrand), Independent CPA’s for P&C Insurance Company, Inc.

Address to be determined.

This witness is expected to testify as to Harmon’s report to him that P&C’s financial statements were fraudulent and in violation of IRS and Insurance Department regulations. He will be asked as to which officer of P&C signed off on the 1996 financial statements, whether the auditors opinion was qualified or unqualified, and why Coopers & Lybrand approved the financial statements when they were previously advised by Harmon that they were fraudulent.

Internet References:

www.the-catbird-seat.net/PriceWaterhouse.htm

www.the-catbird-seat.net/Claims-Branch-PWC.htm

MATT A. TSUKAZAKI, Esq.

Purported attorney for Kamehameha Schools and P&C Insurance Company; purported Claims Adjuster for P&C Insurance Company, Inc. and other unnamed insurance companies.

700 Bishop Street

15th Floor

Honolulu, HI 96813

This witness is expected to testify as to the fact of whether he is a licensed Claims Adjuster for P&C Insurance Co.; facts regarding the Settlement Agreement and the reasons why the law firm of Torkildson, Katz, Fonseca, Jaffe, Moore & Hetherington was not a signatory to the Settlement Agreement. He is expected to testify and produce an Attorney of Record letter evidencing that his firm was legally appointed by Kamehameha Schools, and Federal Insurance Co to represent them in Harmon’s RICO lawsuit and in the settlement negotiations; tax-related issues; relationships with Hamilton McCubbin, P&C Insurance Co., Marsh & McLennan, Aon Insurance, and others.

Internet References:

www.the-catbird-seat.net/Claims-Branch-Torkildson-Katz.htm

MICHELLE H. TUCKER, CPA

Accountant for the Bankruptcy Estate.

Sterling & Tucker

820 Mililani Street, 4^th Floor

Honolulu, HI 96813

This witness is expected to testify as to the tax-related issues, especially with regard to the legality of Mary Lou Woo’s issuance of the IRS Form 1099-MISC against her professional advice, and as to her personal or professional relationships with Susan Tius; Rush Moore Craven Sutton Morry & Beh; Bank of Honolulu; Guido Giacometti; Sukamto Sia; Paul Alston; Alston Hunt Floyd & Ing; Sanford Murata, and others.

RICHARD S.H. WONG

Former Kamehameha Schools/Bishop Estate Trustee; Defendant in EQ2048; Real Party in Interest in CV05-00030 - Woo vs. Harmon

c/o Kenneth Hipp, Esq., Marr Hipp Jones...

1001 Bishop Street, Ste 1550

Honolulu, HI 96813

This witness is expected to testify as to the facts and circumstances of the settlement, and to provide evidence, in the form of an Attorney of Record letter or similar document, that Kenneth Hipp, Esq. was his appointed attorney in Harmon’s RICO lawsuit, and that Mr. Hipp’s appointment was approved, in writing, by Federal Insurance Company. Richard S.H. Wong is also expected to testify regarding his past and present relationships, if any, with Mikah Kane, Mark Construction, Constructors Hawaii, Mark Development, Mark Watase and Craig Watase. Mr. Wong is expected to testify while he was a state senator or Bishop Estate trustee, whether or not Mark Construction, or any of its subsidiaries or subcontractors, ever performed any work on his personal residence, and, if so, the nature and details of that work. Mr. Wong is also expected to testify regarding his involvement, as a legislator, with the federal financing and construction of the H-1 Freeway.

Internet References:

www.the-catbird-seat.net/IRS-Intermediate-Sanctions.pdf

www.the-catbird-seat.net/EQ2048-AG-Trustees-4-27-0.pdf

COLLEEN WONG, ESQ.

Acting CEO and General Counsel, Kamehameha Schools; Recipient of letters from Harmon’s “letter-writing campaign.”

Kamehameha Schools

567 S. King St., Ste 310

Honolulu, HI 96813

This witness is expected to testify as to the facts and circumstances of the settlement, relationships with Bobby Harmon; P&C Insurance Co.; Marr, Hipp, Jones & Pepper; Gilbert Tam; William S. Richardson; Nathan Aipa; Louanne Kam; Lyn Anzai; Hamilton McCubbin; Wally Chin; Sandie Wicklein; Maryanne Inouye; Yukio Takemoto; Robert Katz; Matt Tsukazaki; PricewaterhouseCoopers; Mark McConaghy; Federal Insurance Co.; Marsh & McLennan; Rocco Sansone; John Mullen Company, Inc.; Alston, Hunt, Floyd & Ing; Gensiro Kawamoto; Goldman Sachs; CB Richard Ellis; Susan Tius and Lissa Andrews, Rush Moore LLP; Guido Giacometti; Sukamto Sia; Apollo Advisors; Trinity Investment; Mitsui Bank & Trust Co.; Hawaii Land Use Commission; Maui Planning Commission; Hawaii Dept of Land & Natural Resources, and others yet to be named.

Internet References:

www.the-catbird-seat.net/IRS-Intermediate-Sanctions.pdf

www.the-catbird-seat.net/EQ2048-AG-Trustees-4-27-0.pdf

www.the-catbird-seat.net/Doc-EQ2048-AG-Witnesses-5-19-0.pdf

MARY LOU WOO

Claimant & Ch. 7 Trustee in Case No. 99-04339; Signatory to Settlement Agreement.

c/o Steven Guttman, Esq.

Kessner, Duca, Umebayashi, Bain & Matsunaga

220 South King St., 19^th Flr.

Honolulu, HI 96813

This witness is expected to testify as to the facts and circumstances of the settlement and the actions taken by Respondent subsequent to his signing of the Agreement, including tax-related issues; and conflicts-of-interests issues involving Susan Tius, Steven Guttman, Sterling & Miller, others.

Internet References: