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was providing. Petitioners rarely, if ever, spoke with the
management of these resorts.
On a number of occasions, other members of the “WVI management
team” accompanied petitioners on these trips. On at least one
occasion each, David Legere (president of Offsite) and Senator
Stanley Walker, along with their spouses, traveled with petitioners
and had their expenses paid by WVI. On these trips, petitioners
and their associates stayed at first-class resorts and dined at the
finest restaurants. During their December 1990 trip to Hawaii,
petitioners stayed at the Halekulani Hotel for $850 per night and
dined at the La Mer restaurant for meals costing $900 or more; the
next month they stayed at the Lodge at Koele for $900 per night and
dined at expensive restaurants, with one meal costing over $2,000.
On these trips, petitioners enjoyed room service and many of
the local attractions. Over the course of 4 days, petitioners
incurred $462 in room service charges. During this same period,
petitioners visited local tourist attractions such as Sea Life
Park, Ala Moana shopping center, and the Waipio Valley historical
site.
During the audit for the years in question (discussed infra),
Dr. Gow was requested to provide itineraries for the trips to
Hawaii and Key West. These itineraries, which purport to summarize
petitioners’ activities during those trips, were reconstructed by
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