Epstein Secrets

ofessional Building. 9053 Estate Thomas. Suite 101. St. Thomas. VI. 00802 iereonore I max I January 18, 2019 Via Hand & Electronic Delivery: Mr. Jean-Pierre Oriol Commissioner Department of Planning and Natural Resources Division of Coastal Zone Management Cyril E. King Airport Terminal Building 2nd Floor

wire repair, and repairs to water heaters and purifiers, for which no permit is required pursuant to the definition of "development" set forth in 12 V.I.C. § 902(1). Likewise, Great St. Jim's repair of boats, solar equipment, generators, and other equipment and other activities including water delivery

Unauthorized and Unlass ful Elfin 16. On October 28, 2016, three (3) DPNR representatives, including an armed enforcement officer, Officer Mercer, Jean-Pierre Oriol, Director of Coastal Zone Management, and Attorney Michele Baker, DPNR Legal Counsel, entered upon Great St. James without prior notice to or appro

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

he Unauthorized and Unlawful Entry 16. On October 28, 2016, three (3) DPNR representatives, including an armed enforcement officer, Officer Mercer, Jean-Pierre Oriol, Director of Coastal Zone EFTA00583143 GS!, LLC v. DPNR et al. Civil No. 12017 Complaint Page 4 Management, and Attorney Michele Baker, DPNR

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

ed. The Unlawful Entry and Search 24. On October 28, 2016, three (3) DPNR representatives, including an armed enforcement officer, Officer Mercer, Jean-Pierre Oriol, Director of CZM, and Attorney Michele Baker, DPNR Legal Counsel, entered upon Great St. James without prior notice to or EFTA00583162 GSI LLC v.

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

he Unauthorized and Unlawful Entry 16. On October 28, 2016, three (3) DPNR representatives, including an armed enforcement officer, Officer Mercer, Jean-Pierre Oriol, Director of Coastal Zone EFTA00583187 GS!, LLC v. DPNR et al. Civil No. 12017 Complaint Page 4 Management, and Attorney Michele Baker, DPNR

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

Department of Planning and Natural Resources 8100 Lindberg Bay, Suite 61 Cyril E. King Airport Terminal Building. 2nd Floor St. Thomas, VI 00802 Jean-Pierre Oriol Director DPNR — Division of Coastal Zone Management 8100 Lindberg Bay, Suite 61 Cyril E. King Airport Terminal Building. 2nd Floor St. Thomas,

essional Building, 9053 Estate Thomas, Suite 101, St. Thomas, V.I. 00802 340.779.2564 Telephone I 1.888.316.9269 Fax I www.kellfercom prohibited.12 V.I.C. § 94. Because GSJ is privately, not publicly, owned, the Commissioner of Conservation and Cultural Affairs does not control or supervise it, and, th