LEGAL ADDRESS. 1801 N. Drexel Street Dearborn, M1 48128 MAILING ADDRESS: 2591 Dole Street Hale Wainani Dorm, Building H, Room 258 Honolulu, HI 96822 Phone Number: (313) 510-7597 Email: Stephen Young@protonmail.com IN THE OAHU FIRST CIRCUIT COURT FOR THE STATE OF HAWAII YOUNG, STEPHEN R.N., CIV. ACTION NO. ty. 1-055 S04 Plaintiff, BIA CATEGORY “ OTHER CIVIL ACTION THE UNVERSITY OF HAWAII SYSTEM AND THE UNIVERSITY OF HAWAII, COMPLAINT KAWAKAMI, RONETTE M., Defendant INTRODUCTORY STATEMENT This case arises under the Uniform Information Practices Act of 1988 (“UIPA") under HRS § 92F, Office of Information Practices (henceforth “OIP”) rules and regulations regarding responding to UIPA requests for information; and disputes regarding the interpretation of U.S.C.A. § 1232 (specifically section g) (“FERPA”), 34 C.F.R. § 99,31 (°FERPA”: Conditions in which PAGE 1 OF 22 —on. In this action, Plaintiff Stephen Robert Neale Young (henceforth “Stephen Young"), was, and currently is, Ist year law student atthe William S. Richardson School of Law (also referred to as the “WSRSL"), alleges that Defendant The University of Hawaii System (henceforth the University of Hawaii) failed to meet the requirement for a timely response toa UIPA request under UIPA and O1P rules and regulations, violated his right to access information under the UIPA without just cause or reason, and has wasted both the First Circuit Court of Hawaii and the Plainti's time by making frivolous justifications in a manner inconsistent with the requirements ofthe UIPA and common law rulings regarding UIPA necessitating this complaint Plaintiff seeks damages consistent with a failure to respond to a UIPA request within 10 business days, emotional damage caused by the actions ofthe Defendant in attempting to prohibit the Plaintiff's abili to ‘iny challenge the rade the Plaintiff received in Tors for the Fall of 2018 semester, additional requests contained within the Request for Relief Section of this complain, reasonable lepal fees as determined bythe First Circuit Cour, and any farther elie as the Court shall deem just and proper. 1. The First Cieuit Court of Hawaii has jurisdiction over the subject matter ofthis, action under HRS § 92F-27 1 2. The First Circuit Court of Hawaii has jurisdiction under this matter as a result of te Plaintiff having exhausted the appropriate administrative remedies under HRS § 92F-23 as required by HRS § 92F-27 1 PAGE 2 OF 22,OIP because a both the Plaintiff and Defendant currently reside in Honolulu and the records requested are located in Honolulu 4. An individual does not need to appeal to the OIP before filing a lawsuit. Haw. Rev. Stat, § 92F-15.5, PARTIES 5. PlaimtifT Stephen Young isa thirty-one-year-old citizen of the United States and of the State of Michigan, At all times relevant hereto, Plaintiff Young has been a student at The [University of Hawaii at Manoa Campus, studying at its William S. Richardson Law School in Honolulu, Hawaii, and residing in The University of Hawaii Dorms. Plaintiff Stephen Young is a first-year law student and is currently in an adversarial role with the University of Hawaii due to future litigation regarding civil and constitutional rights, in addition to the intemal academic erievance policy of the WSRSL. 6. Defendant the University of Hawaii is a system of 10 public (non-profit) colleges including the University of Hawaii at Manoa, The University of Hawaii's primary office is located Jon the University of Hawaii at Manoa Campus atthe building which houses the General Counsel's (Office. For the purpose of this complaint, due to how interwined the University of Hawaii System 4s with the University of Hawaii at Manoa Campus, both are referred to collectively as the University of Hawaii, The address for the Un ersity of Hawaii is 2444 Dole St, Honolulu, HI }96822. The William S. Richardson Schoo! of Law is located at the University of Hawaii at Manoa |Campus. The University of Hawaii is represented by the General Counsel's Office who has ‘"ppointed, at the request of the WSRSL Dean Aviam Soifer, attomey Derek Mayeshiro. For the Purposes of this specific complaim, a it is an appeal based on a response to a UIPA request, the PAGE 3 OF 22