Epstein Secrets

to counsel of record on January 23, 2020 to: CHRISTOPHER ALLEN KROBLIN, ESQ. ANDREW W. HEYMANN, ESQ., WILLIAM BLUM, ESQ. SHAR1 D'ANDRADE, ESQ. MARJORIE WHALEN, ESQ. KELLERHALS FERGUSON KROBLIN PLLC Royal Palm Professional Building 9053 Estate Thomas, Suite 101 St. Thomas, V.I. 00802-3602 ele Email: 8

ed in carrying out, facilitating and concealing Epstein's crimes, hence Little St. James became an instrumentality of those crimes. 25. Defendant, Great St. Jim, LLC, is a limited liability company established and organized under the laws of the Virgin Islands. Great St. Jim, LLC was organized on October 26,

s president of Poplar, Inc. and expressly authorizes the incorporators to conduct "transactions related to permitting matters submitted on behalf of Great St. Jim, LLC." 30. Poplar, Inc. is listed as the signatory for the 2017 Annual Report for Great St. Jim, LLC, and the signature appears to be Epstein's. T

nd post judgment interest to which it is entitled. Respectfully, Dated: March 8, 2017 ERIKA A. KELLERHALS, ESQ. CHRISTOPHER ALLEN KROBLIN, ESQ. MARJORIE WHALEN, ESQ. V.I. Bar Nos. 849, 966 & R2019 KELLERHALS FERGUSON KROBLIN PLLC Royal Palms Professional Building 9053 Estate Thomas, Suite 101 St. Thomas

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

, DPNR entered onto the premises of Great St. James and traversed the entire island without restriction, allegedly to conduct a "site inspection" of Great St. James, and verbally instructed workers to cease and desist from further activity on Great St. James. 19. This unauthorized entry and search was particula

nd post judgment interest to which it is entitled. Respectfully, Dated: March 8, 2017 ERIKA A. KELLERHALS, ESQ. CHRISTOPHER ALLEN KROBLIN, ESQ. MARJORIE WHALEN, ESQ. V.I. Bar Nos. 849, 966 & R2019 KELLERHALS FERGUSON KROBLIN PLLC Royal Palms Professional Building 9053 Estate Thomas, Suite 101 St. Thomas

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

sment of Two Hundred Eighty Thousand Dollars ($280,000.00) for what DPNR alleged were violations of the Coastal Zone Management Act on the island of Great St. James. [EXHIBIT A] 8. GSJ vehemently contested both the alleged violations and the outrageous assessment as unjustified and well outside the scope of DPN

post judgment interest to which it is entitled. Respectfully, Dated: March 412, 2017 ERIKA A. KELLERHALS, ESQ. CHRISTOPHER ALLEN KROBLIN, ESQ. MARJORIE WHALEN, ESQ. V.I. Bar Nos. 849, 966 & R2019 KELLERHALS FERGUSON KROBLIN PLLC Royal Palms Professional Building 9053 Estate Thomas, Suite 101 St. Thomas

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

FFORT OF CLAIMS Amount Unknown Amounts to Be Determined Amount to Bc Determined Respectfully submitted, P KROBLIN, ESQ. WILLIAM L BLUNI, ESQ. MARJORIE WHALEN, ESQ. SHARI D'ANDRADE, ESQ. Kellerhals Ferguson Kroblin PIJ.0 EFTA00082468 I, DARREN K. INDYKE, CO-EXECUTOR BEM FIRST MALY SWORN DEPOSE AND SAY

effrey Epstein, Case No. 502019CA16311 Government of the United States Virgin Islands v. Estate of Jeffrey E. Epstein, The 1953 Trust, Plan D, LLC, Great St. Jim, LIE, Nautilus, Inc., Hyperion Air, LIC, Polar, Inc, John and Jane Does v. 1953 Trust, Estate of the deceased Jeffrey R Epstein, & Mark Epstein J

post judgment interest to which it is entitled. Respectfully, Dated: March 4422, 2017- ERIKA A. KELLERHALS, ESQ. CHRISTOPHER ALLEN KROBLIN, ESQ. MARJORIE WHALEN, ESQ. V.I. Bar Nos. 849, 966 & R2019 KELLERHALS FERGUSON KROBLIN PLLC Royal Palms Professional Building 9053 Estate Thomas, Suite 101 St. Thomas

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