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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
ned so that barges can approach and land on the end of the dock while vessels can dock along the "L". After the hurricane Irma in 2017 the owner of the Great St. James assisted many of his employees and their families who had lost their homes and housed people on the island. In order to bring in emergency supplies
c Survey, Historic Artifact Locations Tropical Marine, Red Hook, St Thomas, VI — Carlos Ruan/Tropical Marina - Hydrographic Survey, Dock Permitting Great St James & Little St James Islands, VI —Great St Jim, LLC — Hydrographic Surveys, Wetland Locations, Dock & Environmental Permitting Greenside Properties, Inc,
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
t the Department of Planning and Natural Resources and Commissioner Dawn Henry, states and alleges as follows: PARTIES & JURISDICTION 1. Plaintiff Great St. Jim, LLC ("GSJ") is a limited liability company organized under the laws of the U.S. Virgin Islands. 2. Upon information and belief, Defendant the Depa
el for DPNR made no attempt whatsoever to contact the undersigned legal counsel for prior approval or to notify GSJ before the unauthorized entry on Great St. James, the communication with GSJ personnel without permission, and the unlawful search. 23. By refusing to comply with the conditions of the permit and
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.
t the Department of Planning and Natural Resources and Commissioner Dawn Henry, states and alleges as follows: PARTIES & JURISDICTION 1. Plaintiff Great St. Jim, LLC ("GSJ") is a limited liability company organized under the laws of the U.S. Virgin Islands. 2. Upon information and belief, Defendant the Depa
Entities connected to both Coastal Zone Management and Great St. James

Jeffrey Epstein
PERSON
U.S. Virgin Islands
LOCATIONErika Kellerhals
PERSON
Sarah Ferguson
PERSON
Richard Kahn
PERSON
Jean-Pierre Oriol
PERSONV.I.C.
ORGANIZATION
Red Hook
LOCATION
Michael Barker
PERSON
James Baker
PERSONDaphne Wallace
PERSONCecile de Jongh
PERSONJohn P. Woods
PERSON
Little St.
LOCATIONMARJORIE WHALEN
PERSON
Woody Allen
PERSONDawn Henry
PERSONV.I. Bar Nos
ORGANIZATIONERIKA A. KELLERHALS
PERSON
Marc Rich
PERSON