4
Shared Docs
4
Same-Page
7 / 4
Mentions
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
IN PLLC, and for its Complaint against 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 an
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
IN PLLC, and for its Complaint against 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 an
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
IN PLLC, and for its Complaint against 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 an
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
IN PLLC, and for its Complaint against 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 an
Entities connected to both Great St. James and PARTIES & JURISDICTION

U.S. Virgin Islands
LOCATION
Sarah Ferguson
PERSONV.I.C.
ORGANIZATION
Jean-Pierre Oriol
PERSON
Red Hook
LOCATION
James Baker
PERSON
Michael Barker
PERSONMARJORIE WHALEN
PERSON
Woody Allen
PERSONDawn Henry
PERSONV.I. Bar Nos
ORGANIZATIONERIKA A. KELLERHALS
PERSONMercer
PERSON
Emblematic
PERSONOfficial Capacity
ORGANIZATIONNotice of Violation
ORGANIZATIONDPNR Legal Counsel
ORGANIZATIONthe Notice of Failure to
ORGANIZATIONthe Two Hundred Ten Thousand Dollar
ORGANIZATIONthe Board of Land Use Appeals
ORGANIZATION