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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
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
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
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
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
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 MARJORIE WHALEN and ICELLERHALS FERGUSON KROBLIN PLLC

Sarah Ferguson
PERSON
Woody Allen
PERSONV.I. Bar Nos
ORGANIZATIONV.I.C.
ORGANIZATION
U.S. Virgin Islands
LOCATION
Great St. James
ORGANIZATIONOfficial Capacity
ORGANIZATION
Jean-Pierre Oriol
PERSONMercer
PERSON
Michael Barker
PERSON
James Baker
PERSONERIKA A. KELLERHALS
PERSONDawn Henry
PERSONthe Board of Land Use Appeals
ORGANIZATION
Emblematic
PERSONthe Two Hundred Ten Thousand Dollar
ORGANIZATIONthe Notice of Failure to
ORGANIZATION
Red Hook
LOCATIONPARTIES & JURISDICTION
ORGANIZATIONNotice of Violation
ORGANIZATION