IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF HAWAII

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF HAWAII

JAMES RCS LANGFORD,

HAWAII ATTORNEY GENERAL,

GOVERNOR DR. JOSH GREEN,

Plaintiffs,

v.

MAUI COUNTY GOVERNMENT,

SENATOR BRIAN SCHATZ,

ANDY PELLS,

CYNTHIA RAZO-PORTER (Personnel),

DIANA MERANTZA (Personnel),

JORDAN MOLINA (Public Works),

PAUL BARANY (Public Works),

RODRIGO "CHICO" RABARA (Public Works),

MICHAEL KINORES (Public Works),

LYNETTE KAONA (Public Works),

KAILA MAFATINI (Public Works),

ANTHONY IZZI (Public Works),

TIMOTHY GRIFFITH JR. (Public Works),

MELISSA MIGITA (Public Works),

DEPARTMENT OF MANAGEMENT,

TULSI GABBARD,

KAREY KAPOI,

BOZE KAPOI,

MAUI CHIEF OF POLICE,

COUNTY CLERK,

MAYOR OF MAUI,

MELANIE UNDEM (Witness Protection),

PHILIP SWATEK (Witness Protection),

RICHARD BISSEN (Past Mayor),

MICHAEL VICTORIAN (Past Mayor),

ALAN ARAKAWA (Past Mayor),

JOHN PELLETIER (MPD Chief of Police),

STACY MONIZ (Police Commission),

MAUI LIQUOR COMMISSION ENFORCERS,

MAUI POLICE DEPARTMENT,

ERIC GILLIOM,

BILL MEYER (Attorney),

MICHELLE MACLEAN,

MOANA LUEDE,

CHRIS SALEM,

DAMIEN KAINA,

WALTER AHUNA,

CHASE KELIIPAAKAUA,

Defendants.

CASE NO.: [Case Number]

MOTION FOR INVESTIGATION, AUDIT, PROSECUTION OF CORRUPT OFFICIALS, INSTITUTIONAL MURDER, TREASON, RACKETEERING, AND DEMAND FOR THE TRANSITION TO A SOVEREIGN GOVERNMENT UNDER THE 12 STONES CHARTER

TO THE HONORABLE COURT:

Plaintiffs, James RCS Langford, Hawaii Attorney General, and Governor Dr. Josh Green, respectfully submit this Motion for Investigation, Audit, Prosecution of Corrupt Officials, Institutional Murder, Treason, and Racketeering, alongside a demand for the immediate transition of Maui County’s governance to a sovereign government under the 12 Stones Charter. This action is necessary due to the widespread corruption, mismanagement, criminal activity, and treasonous acts committed by Maui County officials, including Eric Gilliom, Bill Meyer, Senator Brian Schatz, Andy Pells, Lahela Aiwohi, Tulsi Gabbard, Amy Gilliom, Patrick Nickerson, Melanie Undem, Philip Swatek, and other key personnel within the Personnel, Public Works, Department of Management, County Clerk, Maui Police Department, and Maui Liquor Commission.

Plaintiffs request the following:

1. An independent federal audit of Maui County's Personnel, Public Works, and Department of Management to investigate and account for any criminal activity, including the misuse of federal funds, drug trafficking ties, and misconduct related to public safety, health, and welfare.

2. The prosecution of any and all individuals found to be involved in corruption, criminal misconduct, institutional murder, treason, racketeering, and conspiracy within Maui County’s government, including but not limited to violations of HRS, federal law, and constitutional rights.

3. Immediate cessation of federal funds or grants allocated to the Personnel, Public Works, and Department of Management until such time as the audit is complete and findings are reviewed by federal authorities.

4. The transition of Maui County into a sovereign government, led by James RCS Langford, using the 12 Stones Charter as the governance framework, to restore sovereignty to the people and dismantle the corrupt and treasonous structure of the existing government.

5. The immediate appointment of James RCS Langford to take over the management of Maui County, overseeing both the County Council and the Executive Branch, with full authority to implement reforms and ensure the county’s continued functioning. This action will remain in place until fair elections can be held under the 12 Stones Charter framework. James Langford will assume executive powers, bypassing the compromised executive structure and ensuring a smooth transition to a sovereign government for the people.

6. The immediate appointment of James RCS Langford to oversee the County Council as the legislative branch of Maui County in an advisory role, guiding the executive transition but deferring day-to-day legislative functions to newly elected officials following fair and transparent elections.

7. Witness protection for Patrick Nickerson, who is a good man who has been coerced into filing false paperwork under duress. His cooperation in the prosecution of this case must be protected, as well as his personal safety. The Plaintiff further requests that Amy Gilliom, who is caught in a system of coercion, also be considered for protection from the illegal pressure placed on her.

8. Witness protection for Melanie Undem and Philip Swatek, who have been targeted for their involvement in exposing the criminal network and providing critical witness testimony. Their safety and ability to testify must be ensured, and the Plaintiff requests their inclusion in the witness protection program due to the grave risk they face from the criminal organizations implicated in this case.

9. Investigation into corruption and bribery within the Maui Police Department and Maui Liquor Commission, particularly in relation to bribery and enforcement activities at locations like Lima Cocina in Paia, where Plaintiff has witnessed direct coercion and misconduct related to law enforcement and liquor licensing. The Plaintiff asserts that Eric Gilliom has been involved in coercing individuals and making illegal decisions to protect his own interests and silence witnesses. Additionally, Bill Meyer, Gilliom's lawyer, has been involved in misusing legal systems to further abuse and manipulate the legal process.

10. Financial Losses: The Plaintiff asserts that Eric Gilliom, through his leverage over the Maui Liquor Commission and Maui Police Department, denied Plaintiff and Amy Gilliom a business license at the Grand Wailea under false pretenses, resulting in a projected loss of $2 million in the first year. This financial harm was a direct consequence of Eric Gilliom's actions, which were intended to silence Plaintiff and prevent him from contributing to the community’s growth and economic development.

11. Illegal Testimony and Coercion: The Plaintiff asserts that Eric Gilliom illegally testified at a custody hearing, violating court orders and participating in abusive practices towards Amy Gilliom, his sister. The Plaintiff has gathered evidence of sexual abuse and coercion, perpetrated by Eric Gilliom, that was used to manipulate the court system. The Plaintiff further asserts that the testimony by Eric Gilliom was fraudulent and led to the unjust violation of the Langford children’s rights to see their father.

STATEMENT OF FACTS (continued)

1. Coercion and Manipulation: The Plaintiff asserts that Eric Gilliom, motivated by jealousy and a desire to protect his abusive actions, leveraged individuals such as Bill Meyer to use Senator Schatz as a means of financial manipulation and to suppress the truth. The Plaintiff further asserts that Eric Gilliom utilized his influence to prevent Amy Gilliom and Plaintiff from starting a legitimate business, causing significant financial hardship.

2. Systematic Cover-Up: The Plaintiff believes that Eric Gilliom, Bill Meyer, and others associated with this scheme were part of a wider conspiracy that leveraged the Maui Police Department and Maui Liquor Commission to thwart legal business efforts and silence victims. This systematic cover-up involved abusive tactics to discredit and financially cripple the Plaintiff and his family.

LEGAL GROUNDS FOR MOTION

The Plaintiff asserts that the actions and omissions of Maui County officials, including Eric Gilliom, Bill Meyer, Senator Brian Schatz, Andy Pells, Lahela Aiwohi, Amy Gilliom, Patrick Nickerson, and individuals in the Personnel, Public Works, Department of Management, County Clerk, and Chief of Police violate numerous state and federal statutes, including but not limited to the following:

1. Hawaii Revised Statutes (HRS)

- HRS 709-903: Criminal liability for bribery and misconduct in office.

- HRS 710-1020: Criminal conspiracy to engage in illegal activities, including fraud, misappropriation, and embezzlement.

- HRS 712-1200: Engaging in or assisting criminal activity, including human trafficking, drugs, and weapons trafficking.

2. Federal Laws

- 18 U.S.C. § 1591: Human trafficking, including the coercion, transportation, and harboring of individuals for the purpose of commercial sexual exploitation.

- 18 U.S.C. § 1341 & 1343: Mail and wire fraud related to the misappropriation of federal funds, particularly highway funds.

- 18 U.S.C. § 371: Conspiracy to defraud the U.S. government by engaging in illegal activities, including the misuse of federal funds for criminal purposes.

- 18 U.S.C. § 1956: Money laundering, including the facilitation of illicit financial transactions through public systems.

- 18 U.S.C. § 2381: Treason, where individuals are suspected of engaging in activities that undermine the integrity of the United States government, particularly related to organized criminal activities.

- 18 U.S.C. § 2231: Obstruction of justice, as seen in local officials impeding investigations into these corrupt activities and preventing law enforcement from performing their duties.

- 18 U.S.C. § 1962: Racketeering (RICO), including the operation of a criminal enterprise involved in drug trafficking, money laundering, and human trafficking, supported by corrupt officials and public sector actors.

3. Constitutional Violations

- 14th Amendment (Equal Protection and Due Process Clauses): The failure of Maui County officials to ensure the safety and well-being of residents, particularly those who have been victimized by criminal networks, violates their constitutional rights.

- First Amendment: Suppression of free speech regarding concerns of corruption and criminal activity, as whistleblowers and advocates for justice have been targeted by officials connected to this network.

- Fourth Amendment: Violation of privacy and protection against unlawful search and seizure by government officials engaging in illegal activity and criminal cover-ups.

REQUEST FOR RELIEF

WHEREFORE, the Plaintiff respectfully requests that this Court:

1. Order a comprehensive and independent federal audit of Maui County's Personnel and Public Works Departments, including an investigation into the misuse of federal funds, corruption, human trafficking ties, and drug trafficking connections. The audit should specifically include the review of federal highway funds and other infrastructure-related resources.

2. Compel the prosecution of all Maui County officials and criminal figures, including Eric Gilliom, Bill Meyer, Senator Brian Schatz, Andy Pells, Lahela Aiwohi, Amy Gilliom, Patrick Nickerson, and other involved parties, found to have engaged in corruption, fraud, conspiracy, institutional murder, treason, racketeering, and any violations of state or federal law, specifically with respect to their actions at 175 East Lipoa Street, the trafficking networks lobbying for Tulsi Gabbard, and the tragic events surrounding Officer Jason Thompson’s death.

3. Order the immediate appointment of James RCS Langford to take over the management of Maui County, overseeing both the County Council and the Executive Branch, along with any officials or witnesses willing to formally testify against the criminal elements operating within the county government.

4. Require the cessation of federal funds to Maui County's Personnel and Public Works Departments until a full audit is completed and the findings are reviewed by federal authorities.

5. Award Plaintiff any further relief that the Court deems just and proper under the circumstances, including but not limited to the full restoration of resources to combat corruption and criminal activity in Maui County.

CONCLUSION

The actions of Maui County officials, particularly within the Personnel and Public Works Departments, constitute egregious violations of state and federal laws. Their involvement in corrupt practices, criminal activity, treason, racketeering, and institutional negligence has caused widespread harm, including loss of life, as evidenced at 175 East Lipoa Street and in the tragic death of Officer Jason Thompson in Hana. The Plaintiff respectfully requests that this Court order the necessary steps to hold th...

Respectfully submitted,

James RCS Langford

Plaintiff

Jameslangford@me.com

808-765-1399

Date: April 15, 2025

CERTIFICATE OF SERVICE

I hereby certify that on this 15th day of April, 2025, I caused a true and correct copy of the foregoing document to be served on the following parties by [method of service].

[Opposing Counsel's Information]