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EXHIBIT 34 Alvin’s Au Files: City “Family Day Participation – July 5, 2003 (as of June 25, 2003)”. 

Shows that as of June 25, 2003, two days before the ACLU lawsuit was filed,  the “Oahu Civil Defense Agency intended to provide 5 “Volunteer vehicles.”  These vehicles are to be used by non-city parade participants.  In addition, Malcolm Tom stated repeatedly during Festival committee meetings that the City intended to provide cars for the beauty queens. The Dept of Transportation intended to provide a float, the DFM intended to provide Vactor Truck,  Flat bed truck, and 2 sweepers.  Also, as of two days before this lawsuit, the Board of Water Supply intended to provide a water wagon. 

This document undermines a number of assertions made by the City.  First, the City represented to the Court that the City did not intend to provide floats or flat bed trucks for the parade.  However, the City failed to provide any hard evidence of that assertion other than self-serving declarations of City officials.  Surely, there should be numerous memorandum and/or emails directing the various City Departments and employees that were to provide these items as of June 25, 2003 not to do so. The City has not produced a single memoranda or email as evidence of it assertions.

If it is true that the City ultimately did not provide any lowboys or flatbed trucks or a water wagon, it is not a stretch to infer that this was an attempt to hide the extent of the City’s involvement in the Family Day Parade, as two days before the lawsuit they still intended to provide all of the above.


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