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Select Exhibits Filed In The Anti-Gay Family Day Parade Case Illistrating City's Involvement In The Parade
(U.S. District Court, Civil No. CV0300332 HGKSC)

EXHIBIT 2 City Advertisement Posted on Website and Mailed to Public.
This document shows that the City is the cosponsor of the entire Family Day Event, including specifically the parade.  The City invites individuals to “join the parade”, and not to join the event in general as the City erroneously claims.  The City also indicated: “Everyone is welcome to join this parade.”  Individuals are directed to call Alvin Au, Director of Facility Maintenance for the City, to participate in the parade.  If this is not a City parade, why does the City direct individuals to call a City employee on City time in his City office to join the parade?

EXHIBIT 12 City and County of Honolulu, Family Day Committee Assignments as of June 18, 2003
This document shows that the Family Day Parade Committee, set up to plan and carry out the parade, was comprised of twelve city members and eight community members.  Alvin Au is the City co-chair of the Parade Committee.  This document shows also show that the Float Committee was comprised of five city members and four community members.  Bill Balfour from the Department of Parks and Recreation for the City is the City co-chair of the Float Committee.  The Float Committee is charged with providing trailers and trucks and organizing the decoration of floats at City locations. The City should not be involved at all with floats if this is not a City parade.

EXHIBIT 25a-b June 27 Mailing from City Office of Managing Director to Michelle Matson of the Diamond Head/Kapahulu/St. Louis Heights Neighborhood Board.
The City mailed a Hawaii Christian Coalition letter, containing scripture, and inviting individuals to join the parade from the City Office of Managing Director in City envelopes and metered postage paid by the city.   The use of taxpayers’ funds to mail out Hawaii Christian Coalition letters soliciting individuals to join the parade strongly suggests that the City is a co-sponsor of the parade, and/or that taxpayer funds are being grossly misused.  Note that this letter was sent on June 27, 2003, the day the ACLU sued regarding the City’s improper support of the Hawaii Christian Coalition’s anti-gay family parade.

EXHIBIT 26 Parade Committee Minutes from files of Alvin Au, City Director of Facility Maintenance, regarding June 4, 2003 City Family Day parade meeting.

First entry indicates that the Corporation Counsel, “finalized parade entry form and rules.  If this is a private parade, Corporation Counsel should not have done this, as it is an abuse of taxpayer resources.

Exhibit 26 also indicates that the City “Mailed flyers and parade applications to 130 veterans groups on Oahu.”  This directly contradicts the City’s assertion that they were not involved in the solicitation of participants for the parade.  In addition, the document indicates that the City “Confirmed participation of Joint Services Color Guard” and made preliminary contact with the “Street Bikers and Classic Car groups.”  Once again, this evidence underscores the City’s active involvement in the solicitation of participants for the parade, as well as substantive determinations as to the content of the parade.
 
EXHIBIT 27a Notes from an early April 16, 2003 meeting of the City discussing the concepts and content of Family Day events. 

This document appears to be notes from an early meeting that the City had regarding the Family Day Event was still in the conceptual phase.  The parade is listed as the first component of the event.  Under “organizations”, it lists potential organizations to take part in the parade including the military, the YMCA, and PAL.  The Hawaii Christian Coalition (HCC) is not mentioned, suggesting that as of April 16, 2003, the HCC was not involved in the event, nor had anyone yet thought to involve them.  This is contrary to the assertion of Mr. Hashimoto that the parade was “his brain child,” this document clearly suggests that as of April 16, 2003, the HCC had not yet expressed any interest in being involved in the parade.
 
EXHIBIT 28 Additional notes from the April 16, 2003 Family Day Meeting.
  
This Document contains the statement: “The following expressed interest in being involved.”  For parade, the following groups are again listed:

Parade
1.    Palama Settlement
2.    Tahiti Nui
3.    YMCA
4.    PAL
5.    Kids Soccer (Max Sword Outrigger)
6.    Shriners (?)
7.    Chinatown. 

Further down on the page there is a category labeled  “ANY” and underneath the following: “Garrett(?)”.  Again this show that as of April 16, 2003, the HCC had not yet expressed any interest in being involved in the parade.  It also shows that Garrett Hashimoto and the Christian Coalition had yet to be confirmed as a sponsor of any Family Day event.  It further indicates that the Christian Coalition and Mr. Hashimoto did not particularly care which event they were involved in.  Read differently, “(?)” suggests that idea of the Hawaii Christian Coalition, as sponsors, was conceived of by City officials at the April 16, 2003 meeting, and that Mr. Hashimoto was later approached by the City.
 
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.

EXHIBIT 41a-b  Document faxed by Stan Fernandez of the Civilian Air Patrol, US Air Force Auxiliary, to Deputy City Manger Malcolm Tom on April 8, 2003.
Fax of form to City Deputy Managing Director Malcolm Tom requesting that the CAP be included on a parade committee.  The form also states that CAP would like to have a “marching unit & vehicles” in the parade. The second page of this exhibit, 41b, is a form for individuals to fill out and submit to indicate their interest in participating in a Family Day committee, or in the parade.  The parade is listed as the first 8 items under the topic committee interests.  Individuals are directed to fax the form to Garrett Hashimoto or Malcolm Tom at his City fax number.  This demonstrates that the City was involved not only in the planning and execution of the parade, but that it used City resources and employees to solicit community members for the parade committee itself.

EXHIBIT 43a-b Diagram showing the structure of the Volunteer Committee and the responsibilities of various volunteer committee members. 

The organizational chart shows that “Mike” is responsible for coordinating parade volunteers, as well as volunteers for transportation/parking, set up, clean up. The next page of the exhibit, 43b, shows that Mike Amii of DCS (City Department of Customer Services) is the only Mike on the Volunteer Committee.  Why would a City employee be coordinating volunteers for the parade if this were the Hawaii Christian Coalition’s private parade?  
 
EXHIBIT 48a, b, c, d.  Typed list of parade participants with handwritten notes from City Director of Facility Maintenance Alvin Au’s files, dated by hand, June 24, 2003.

The top of the page (48a) contains a note: “First draft Parade Line.” Beside each participant is a circled number apparently corresponding to their placement in the parade line.

First, this shows that the City, specifically Alvin Au, made decisions related to the positioning of participants in the parade.  This is a content decision and goes far beyond logistics.  Again, Au prepared this document on city time with city computers only three days before the ACLU lawsuit was filed.

Second, certain items such as a flat-bed (float) for Windward Baptist Church, a lowboy float for United We Stand, two flatbeds for Hispanic Music Group, and 5 cars for pageant finalists display a double asterisk (**).  These asterisks correspond to the items that the City has indicated in other documents, and in statements at meetings, that it intended to provide for other organizations to use in the parade.

For example, Exhibit 12 indicates that organizations would decorate floats at City locations and that the City would provide floats and flat bed trucks and trailers. 

Likewise, Exhibit 34 indicates that the City’s Department of Facility Maintenance will be providing boom trucks, vactor trucks, flat bed trucks and sweepers for use in the parade. In addition, Malcolm Tom stated repeatedly during Festival committee meetings that the City intended to provide cars for the beauty queens.

In addition, during the June 25, 2003 Family Day planning meeting, Mr. Tom indicated that the City would provide city vehicles for the parade, including city police vehicles, fire trucks and city trailers for use as floats, as well as two lowboys and three flatbed trucks to be used in the parade.

 
 
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