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l and territorial law and enforcement authorities. The Department of Planning and Natural Resources ("DPNR") regulates and monitors construction in the Coastal Zone to protect, maintain and manage the precious natural resources of the Virgin Islands. Under its authority, DPNR repeatedly issued citations and asse
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
l and territorial law and enforcement authorities. The Department of Planning and Natural Resources ("DPNR") regulates and monitors construction in the Coastal Zone to protect, maintain and manage the precious natural resources of the Virgin Islands. Under its authority, DPNR repeatedly issued citations and asse
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
l and territorial law and enforcement authorities. The Department of Planning and Natural Resources ("DPNR") regulates and monitors construction in the Coastal Zone to protect, maintain and manage the precious natural resources of the Virgin Islands. Under its authority, DPNR repeatedly issued citations and asse
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
l and territorial law and enforcement authorities. The Department of Planning and Natural Resources ("DPNR") regulates and monitors construction in the Coastal Zone to protect, maintain and manage the precious natural resources of the Virgin Islands. Under its authority, DPNR repeatedly issued citations and asse
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
l and territorial law and enforcement authorities. The Department of Planning and Natural Resources ("DPNR") regulates and monitors construction in the Coastal Zone to protect, maintain and manage the precious natural resources of the Virgin Islands. Under its authority, DPNR repeatedly issued citations and asse
Trust, and numerous Epstein business affiliates and associates for violation of the Criminally Influenced and Corrupt Organization Act ("CICO"). 14 V.I.C. § 600 et seq., and civil conspiracy, seeking forfeiture and divestment of assets in favor of the Government, civil penalties, damages, and other re
red Ten Thousand Dollar ($210,000) assessment against GSJ based on legally and factually deficient claims against GSJ purportedly for violations of the Coastal Zone Management Act (the "Act") on the large private single-family residence known as Great St. James. Such an assessment, of a magnitude never before i
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
l and territorial law and enforcement authorities. The Department of Planning and Natural Resources ("DPNR") regulates and monitors construction in the Coastal Zone to protect, maintain and manage the precious natural resources of the Virgin Islands. Under its authority, DPNR repeatedly issued citations and asse
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
l and territorial law and enforcement authorities. The Department of Planning and Natural Resources ("DPNR") regulates and monitors construction in the Coastal Zone to protect, maintain and manage the precious natural resources of the Virgin Islands. Under its authority, DPNR repeatedly issued citations and asse
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 the Coastal Zone and V.I.C.

U.S. Virgin Islands
LOCATION
Jeffrey Epstein
PERSONDarren Indyke
PERSON
Sarah Ferguson
PERSON
St. John
LOCATION
Richard Kahn
PERSON
Great St. James
ORGANIZATION
New York
LOCATION
St. Croix
LOCATION
George W. Bush
PERSONSouthern Trust Company
ORGANIZATION
United States
LOCATION
Woody Allen
PERSON
Financial Trust Company
ORGANIZATIONHyperion Air
ORGANIZATION
NAUTILUS
ORGANIZATIONNautilus, Inc.
ORGANIZATIONLarry Visoski
PERSONthe Government of the United States Virgin Islands
ORGANIZATIONthe Government of the Virgin Islands
LOCATION