DAVID KEANU SAI,
Acting Minister of Interior
Agent for the Hawaiian Kingdom
P.O. Box 2194
Honolulu, Hawai‘i 96805-2194

NINIA PARKS, Esquire
Attorney for Lance Paul Larsen
P.O. Box 106
Haleiwa, Hawai‘i 96712

September 11, 2000

Her Excellency Phyllis Hamilton, Deputy Secretary General
International Bureau of the Permanent Court of Arbitration
Carnegieplein 2
2517 KJ The Hague
The Netherlands

Re: Joint notification of the Parties Acknowledgement of Procedural Order no. 4 and their Agreement to pleading schedule for a preliminary round as envisaged in Order no. 3

Greetings and Aloha,

We, the undersigned, acting for and on behalf of the Parties, have the honor to inform you that Mr. Lance Paul Larsen, Claimant, and the Government of the Hawaiian Kingdom, Respondent, do jointly confirm and acknowledge Procedural Order no. 4 and shall submit separate pleadings per the schedule proposed by the Arbitral Tribunal as envisaged in Order no. 3, to wit:

"(a) The plaintiff to file a written statement by 30 September 2000;
(b) The defendant to file a written statement by 14 November 2000."

The Parties also request a short oral phase to follow in The Hague to be hereafter determined by agreement between the Parties, the Arbitral Tribunal and the International Bureau of the Permanent Court of Arbitration. May it please the Tribunal to note that the Parties' action in submitting Special Agreement no. 2 was not intended to circumvent Procedural Order no. 3 and/or to undermine the constitution of this esteemed Tribunal, but rather it was our misunderstanding of the order itself. We offer our sincere apology to the Tribunal. After care review of Order no. 3 and further contemplation on the matter, the Parties do understand the preliminary issues raised by the Tribunal and is prepared to submit written pleadings and a short oral phase to address the same.

[signed]

Ninia Parks, Esquire Attorney for the Claimant

[signed]

David Keanu Sai Acting Minister of Interior, Agent for the Respondent

 

cc: Appointing Authority, Mr. Keoni Agard, Esquire