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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
******************* GREAT ST. JIM, LLC, ) ) Plaintiff, ) ) v. ) ) DEPARTMENT OF PLANNING AND ) NATURAL RESOURCES and DAWN HENRY ) In Her Official Capacity as Commissioner of the ) Department of Planning and Natural Resources, ) ) Defendants. ) ) CIVIL NO. 12017 COMPLAINT COMES NOW Plaintiff G
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
******************* GREAT ST. JIM, LLC, ) ) Plaintiff, ) ) v. ) ) DEPARTMENT OF PLANNING AND ) NATURAL RESOURCES and DAWN HENRY ) In Her Official Capacity as Commissioner of the ) Department of Planning and Natural Resources, ) ) Defendants. ) ) CIVIL NO. 12017 COMPLAINT COMES NOW Plaintiff G
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
******************* GREAT ST. JIM, LLC, ) ) Plaintiff, ) ) v. ) ) DEPARTMENT OF PLANNING AND ) NATURAL RESOURCES and DAWN HENRY ) In Her Official Capacity as Commissioner of the ) Department of Planning and Natural Resources, ) ) Defendants. ) ) CIVIL NO. 12017 COMPLAINT COMES NOW Plaintiff G
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
******************* GREAT ST. JIM, LLC, ) ) Plaintiff, ) ) v. ) ) DEPARTMENT OF PLANNING AND ) NATURAL RESOURCES and DAWN HENRY ) In Her Official Capacity as Commissioner of the ) Department of Planning and Natural Resources, ) ) Defendants. ) ) CIVIL NO. 12017 COMPLAINT COMES NOW Plaintiff G
Entities connected to both Red Hook and Official Capacity

U.S. Virgin Islands
LOCATION
Sarah Ferguson
PERSON
Great St. James
ORGANIZATIONV.I.C.
ORGANIZATION
Woody Allen
PERSONV.I. Bar Nos
ORGANIZATIONMARJORIE WHALEN
PERSONERIKA A. KELLERHALS
PERSON
James Baker
PERSON
Michael Barker
PERSONMercer
PERSON
Jean-Pierre Oriol
PERSON
Emblematic
PERSONPARTIES & JURISDICTION
ORGANIZATIONNotice of Violation
ORGANIZATIONDPNR Legal Counsel
ORGANIZATIONthe Notice of Failure to
ORGANIZATIONthe Two Hundred Ten Thousand Dollar
ORGANIZATIONDawn Henry
PERSONthe Board of Land Use Appeals
ORGANIZATION