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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
l Resources, ) ) Defendants. ) ) CIVIL NO. 12017 COMPLAINT COMES NOW Plaintiff Great St. Jim, LLC, by and through its undersigned counsel, ICELLERHALS FERGUSON KROBLIN PLLC, and for its Complaint against the Department of Planning and Natural Resources and Commissioner Dawn Henry, states and alleges as follows: PARTIES
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
l Resources, ) ) Defendants. ) ) CIVIL NO. 12017 COMPLAINT COMES NOW Plaintiff Great St. Jim, LLC, by and through its undersigned counsel, ICELLERHALS FERGUSON KROBLIN PLLC, and for its Complaint against the Department of Planning and Natural Resources and Commissioner Dawn Henry, states and alleges as follows: PARTIES
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
l Resources, ) ) Defendants. ) ) CIVIL NO. 12017 COMPLAINT COMES NOW Plaintiff Great St. Jim, LLC, by and through its undersigned counsel, ICELLERHALS FERGUSON KROBLIN PLLC, and for its Complaint against the Department of Planning and Natural Resources and Commissioner Dawn Henry, states and alleges as follows: PARTIES
Entities connected to both Jean-Pierre Oriol and ICELLERHALS FERGUSON KROBLIN PLLC

Sarah Ferguson
PERSON
Great St. James
ORGANIZATION
Michael Barker
PERSON
James Baker
PERSON
U.S. Virgin Islands
LOCATIONV.I.C.
ORGANIZATIONDawn Henry
PERSON
Woody Allen
PERSONMARJORIE WHALEN
PERSONthe Notice of Failure to
ORGANIZATIONV.I. Bar Nos
ORGANIZATIONERIKA A. KELLERHALS
PERSONthe Two Hundred Ten Thousand Dollar
ORGANIZATIONthe Board of Land Use Appeals
ORGANIZATION
Emblematic
PERSONOfficial Capacity
ORGANIZATIONPARTIES & JURISDICTION
ORGANIZATIONNotice of Violation
ORGANIZATIONDPNR Legal Counsel
ORGANIZATION
Red Hook
LOCATION