Epstein Secrets

a written cease and desist order, M02-16-STT, dated October 28, 2016, that was to be served on counsel for GSJ via email and was delivered to GSJ's Red Hook office on October 31, 2016 (the "Cease and Desist Order"). [EXHIBIT D] Erroneous Notice to Cure & the Arbitrary and Unreasonable Cure Period 33. O

owner was not on the island and that the GSJ personnel present had no authority to grant access to the island, and directed DPNR to GSJ's office in Red Hook. 29. Nevertheless, over the protests of GSJ personnel, and lacking any legal grettedsground or right whatsoever, DPNR illegally entered onto the pre

NR. 4. This action arises out of Defendants violations of DPNR's obligations to GSJ under a settlement agreement with GSJ signed by the Director of Coastal Zone Management ("CZM") on August I, 2016 and Defendant Commissioner Henry on August 4, 2016 (the "Settlement Agreement"). EFTA00583158 GS!, LLC v. DPNR et al.

written cease and desist order, IM-02-16-STT, dated October 28, 2016, that was to be served on counsel for GSJ via email and was delivered to GSJ's Red Hook office on October 31, 2016 (the "Cease and Desist Order"). [EXHIBIT DI Erroneous Notice to Cure & the Arbitrary and Unreasonable Cure Period EFTA0

owner was not on the island and that the GSJ personnel present had no authority to grant access to the island, and directed DPNR to GSJ's office in Red Hook. 21. Nevertheless, over the protests of GSJ personnel, and lacking any legal authority whatsoever, DPNR entered onto the premises of Great St. Jame

el, entered upon Great St. James without prior notice to or approval from GSJ, or any legal authority to do so. 17. DPNR previously issued a minor Coastal Zone Management permit to GSJ in connection with development relating to a certain cistern project (the "Cistern Project") situated at a discrete location on Great

icular Concern (APC) (Figure 5.01.1). The Vessup Bay/Red Hook APC is located on the eastern end of St. Thomas and includes Nazareth, Muller, Vessup, Red Hook, Great Bay, Cowpet Bay, Cabrita, Beck and Water Point, Great St. James, Little St, J, and Dog Island. Areas of Particular Concern in the STEER on

t and prepare both terrestrial and marine Environmental Assessment Report required by the Department of Planning and Natural Resources, Division of Coastal Zone Management, and the U.S. Army Corps of Engineers. Amy Claire Dempsey, principal of Bioimpact, Inc. is certified in wetland delineation by the National Wetland