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DPNR caused a written cease and desist order, =-02-16-STT, dated October 28, 2016, to be served on counsel for GSJ via email and delivered to GSJ's Red Hook office on October 31, 2016 (the "Cease and Desist Order"). [EXHIBIT CI EFTA00583130 GS!, LLC v. DPNR et al. Civil No. / 2017 Complaint Page 5
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. 18. Nevertheless, over the protests of GSJ personnel, and lacking any legal authority whatsoever, DPNR entered onto the premises of Great St. Jame
he implied covenant of good faith and fair dealing, declaratory judgment, and equitable relief over which this Court has jurisdiction pursuant to 4 V.I.C. § 76. EFTA00583127 GS!, LLC v. DPNR et al. Civil No. / 2017 Complaint Page 2 5. Venue is proper in this Court pursuant to 4 V.I.C. § 78, as t
2016, to EFTA00583144 GS!, LLC v. DPNR et aL Civil No. / 2017 Complaint Page 5 be served on counsel for GSJ via email and delivered to GSJ's Red Hook office on October 31, 2016 (the "Cease and Desist Order"). [EXHIBIT CI Erroneous Notice to Cure & the Arbitrary and Unreasonable Cure Period 21. 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. 18. Nevertheless, over the protests of GSJ personnel, and lacking any legal authority whatsoever, DPNR entered onto the premises of Great St. Jame
he implied covenant of good faith and fair dealing, declaratory judgment, and equitable relief over which this Court has jurisdiction pursuant to 4 V.I.C. § 76. EFTA00583141 GS!, LLC v. DPNR et al. Civil No. / 2017 Complaint Page 2 5. Venue is proper in this Court pursuant to 4 V.I.C. § 78, as t
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
he implied covenant of good faith and fair dealing, declaratory judgment, and equitable relief over which this Court has jurisdiction pursuant to 4 V.I.C. § 76. EFTA00583160 GSI LLC v. DPNR et al. Civil No. / 2017 Complaint Page 4 13. Venue is proper in this Court pursuant to 4 V.I.C. § 78, as t
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
he implied covenant of good faith and fair dealing, declaratory judgment, and equitable relief over which this Court has jurisdiction pursuant to 4 V.I.C. § 76. EFTA00583185 GS!, LLC v. DPNR et al. Civil No. / 2017 Complaint Page 2 5. Venue is proper in this Court pursuant to 4 V.I.C. § 78, as t
omas, V.I., as delineated on P.W.D. File No. F9-372-T59 viz: Map P.W.D. File No. F9-372-159 shows that Tracts Nos. I and 2 are in Estate Nazareth, Red Hook, and not on Great St. James Islands. Map P.W.D. File No. F9-372-T59 is attached as Exhibit 5. Using Parcel II to access the Island was not to benefi
mplaint Page 9 "[I]n analyzing an express easement courts are required to determine if the easement satisfies the Statute of Frauds pursuant to 28 V.I.C. 241, which requires a deed of conveyance or other instrument to be in writing." SBRMCOA, LLC v. Morehouse Real Estate Investments, LLC, No. ST-14-
, Inc. is solely owned by Mr. Jeffrey E. Epstein. OTHER FINDINGS: Southern Trust Company, Inc. is a tenant at the American Yacht Harbor, located in Red Hook, St. Thomas, US Virgin Islands. Mr. Jeffrey E. Epstein is a passive investor in IGY-AYH St. Thomas, LLL d/b/a American Yacht Harbor. By letter dat
1, 2017 Additionally, the Beneficiary will donate 50% of its annual charitable contribution to public school program and initiatives pursuant to 29 V.I.C. § 708(m). REQUIRED BY TAX INCENTIVE CERTIFICATE 2013 2014 2015 2016 2017 PUBLIC SCHOOL PROGRAMS AND INITIATIVES 525,000 S 56.000 S 55,696
uss:ash ;dram ends aree Sect** the yonsety el the Mme Wetness stray Mode wee In rebeion to the Sank Wench .4gre the sccount le domicile. MCCenta at Red Hook and WisLIrogit brunches .".it 'Par w. ,.....sxrct•nen r Porn* on!, {ten an accauntn Has, Rey &arch) ins Bare Once owing the accotee -.75IWAGT4Ht4
SING AND CONSUMER AFFAIRS UCENSING DIVISION HEREBY LIMES %NOM That, in accordance with the applicable provisions of Title 3 Chapter 16 and Tile 27 V.I.C. mauling to the licensing of businesses and occupations, and compliance having been made wrth the provisions of 10 V.I.C. Sec. 41 relating to the Ci
pstein GVI's First Amended Complaint Page 8 of 55 Trust Company in September 2012. Southern Trust Company is a tenant at American Yacht Harbor in Red Hook, St. Thomas, and Epstein is a "passive investor" in IGY-AYH, d/b/a American Yacht Harbor. By the end of 2013, according to its corporate filings, So
tates Virgin Islands (herein after "Virgin Islands") brings this action on behalf of the Plaintiff, Government of the Virgin Islands, pursuant to 3 V.I.C. § 114 and her statutory authority to enforce the laws of the Virgin Islands, and advocate for the public interest, safety, health and well-being of
Informatics, Inc., but changed its name to Southern Trust Company in September 2012. Southern Trust Company is a tenant at American Yacht Harbor in Red Hook, St. Thomas, and Epstein is a "passive investor" in IGY-AYH, d/b/a American Yacht Harbor. By the end of 2013, according to its corporate filings, So
ations of Trafficking Victims Protection Act, 18 U.S.C. §§ 1591 to 1595, the Virgin Islands Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 600 to 614, and the Virgin Islands Consumer Fraud and Deceptive Business Practices Act, 12A V.I.C. §§ 301 to 336, and in support thereof alleges
Informatics, Inc., but changed its name to Southern Trust Company in September 2012. Southern Trust Company is a tenant at American Yacht Harbor in Red Hook, St. Thomas, and Epstein is a "passive investor" in IGY-AYH, d/b/a American Yacht Harbor. By the end of 2013, according to its corporate filings, So
ations of Trafficking Victims Protection Act, 18 U.S.C. §§ 1591 to 1595, the Virgin Islands Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 600 to 614, and the Virgin Islands Consumer Fraud and Deceptive Business Practices Act, 12A V.I.C. §§ 301 to 336, and in support thereof alleges
Entities connected to both Red Hook and V.I.C.

Jeffrey Epstein
PERSON
U.S. Virgin Islands
LOCATION
Richard Kahn
PERSONDarren Indyke
PERSONBanco Popular
ORGANIZATION
George W. Bush
PERSON
Marc Rich
PERSON
Sarah Ferguson
PERSON
St Thomas
LOCATIONLarry Visoski
PERSON
United States
LOCATION
JPMorgan Chase
ORGANIZATION
St. John
LOCATION
Condoleezza Rice
PERSON
New York
LOCATION
Great St. James
ORGANIZATION
Charlotte Amalie
LOCATION
Woody Allen
PERSON
Financial Trust Company
ORGANIZATIONDaphne Wallace
PERSON