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of its costs and reasonable attorneys' fees, and any pre and 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 Professi
onable duration after proper and adequate notice of any alleged violation to be cured. I On January 17, 2017, GSJ appealed the Notice of Failure to the Board of Land Use Appeals. This action, however, raises entirely separate causes of action derived from the Settlement Agreement provisions. EFTA00583136 GS!, LLC v. DPNR
of its costs and reasonable attorneys' fees, and any pre and 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 Professi
onable duration after proper and adequate notice of any alleged violation to be cured. I On January 17, 2017, GSJ appealed the Notice of Failure to the Board of Land Use Appeals. This action, however, raises entirely separate causes of action derived from the Settlement Agreement provisions. EFTA00583150 GS!, LLC v. DPNR
f its costs and reasonable attorneys' fees, and any pre and 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 Professi
required notice or a duration for the contractually required cure period, the Settlement On January 17, 2017, GSJ appealed the Notice of Failure to the Board of Land Use Appeals. This-aetienThe present Complaint however, raises entirely separate causes of action derived from the breach of the contractually agreed to Settlem
f its costs and reasonable attorneys' fees, and any pre and 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 Professi
onable duration after proper and adequate notice of any alleged violation to be cured. I On January 17, 2017, GSJ appealed the Notice of Failure to the Board of Land Use Appeals. This action, however, raises entirely separate causes of action derived from the Settlement Agreement provisions. EFTA00583196 GS!, LLC v. DPNR
Entities connected to both ERIKA A. KELLERHALS and the Board of Land Use Appeals

Sarah Ferguson
PERSON
U.S. Virgin Islands
LOCATION
Woody Allen
PERSONV.I.C.
ORGANIZATION
James Baker
PERSONMARJORIE WHALEN
PERSON
Great St. James
ORGANIZATION
Michael Barker
PERSONMercer
PERSON
Red Hook
LOCATION
Jean-Pierre Oriol
PERSONOfficial Capacity
ORGANIZATIONPARTIES & JURISDICTION
ORGANIZATIONNotice of Violation
ORGANIZATIONDPNR Legal Counsel
ORGANIZATIONthe Notice of Failure to
ORGANIZATIONthe Two Hundred Ten Thousand Dollar
ORGANIZATIONV.I. Bar Nos
ORGANIZATIONDawn Henry
PERSON
Emblematic
PERSON