HRS 0480-0024 ANNOTATIONS

Relation back of counterclaim to date of complaint. 473 F. Supp. 1296.

Plaintiffs may recover for §480-2 violations which occurred prior to four-year statute of limitations if they can prove fraudulent concealment; series of fly-drive arrangements constituted alleged continuing violation; section did not bar claims for fly-drives occurring less than four years prior to filing of action. 491 F. Supp. 1199.

If State proved a continuing violation, it would be entitled to seek provable damages for the entire period of the continuing violation; this could include damages that might have occurred prior to the four years before suit was filed, if the continuing violation occurred during that period. 168 F. Supp. 2d 1180.