Wait, I just re-read what you wrote. Seems that you agree that the seal must be next to the director’s signature for those situations listed. What is listed is verifications of documents where the official seal is typically used or where the director decides to use the official seal to verify.
Fuddy could decide to use the official seal to verify a letter of verification, though I’m not sure if full faith and credit would have to apply then, because Fuddy was not the custodian of the record; Onaka was.
But if she decided to use the seal to verify the document then she MUST have the seal near her signature.
Seems like you are agreeing about that.
Well, that’s a problem, because the official DOH seal was used on the so-called letters of verification but it was NOT near her signature. Her signature was nowhere on those documents.
IOW, those documents were NOT certified. For that seal to verify anything - according to the statute authorizing the use of the official seal - it had to be used near her signature. And she didn’t put her signature on those documents.
Why didn’t she?
BTW, apparently the director of health does not sign or stamp notaries public commission any more. The attorney general does.