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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
an arbitrary and unreasonably short cure period, all in clear violation of DPNR's obligations and GSJ's rights under the Settlement Agreement. 24. Emblematic, though not an exhaustive list, of alleged violations DPNR improperly asserted against GSJ in the Notice to Cure were the following: a. An alleged
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
an arbitrary and unreasonably short cure period, all in clear violation of DPNR's obligations and GSJ's rights under the Settlement Agreement. 24. Emblematic, though not an exhaustive list, of alleged violations DPNR improperly asserted against GSJ in the Notice to Cure were the following: a. Alleged vio
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
an arbitrary and unreasonably short cure period, all in clear violation of DPNR's obligations and GSJ's rights under the Settlement Agreement. 35. Emblematic, though not an exhaustive list, of alleged violations DPNR improperly asserted against GSJ in the Notice to Cure were the following: a. An alleged
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
an arbitrary and unreasonably short cure period, all in clear violation of DPNR's obligations and GSJ's rights under the Settlement Agreement. 28. Emblematic, though not an exhaustive list, of alleged violations DPNR improperly asserted against GSJ in the Notice to Cure were the following: a. An alleged
Entities connected to both ERIKA A. KELLERHALS and Emblematic

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Sarah Ferguson
PERSON
U.S. Virgin Islands
LOCATIONV.I.C.
ORGANIZATION
Woody Allen
PERSON
James Baker
PERSONMercer
PERSON
Red Hook
LOCATION
Jean-Pierre Oriol
PERSON
Michael Barker
PERSONthe Board of Land Use Appeals
ORGANIZATIONOfficial Capacity
ORGANIZATIONPARTIES & JURISDICTION
ORGANIZATIONNotice of Violation
ORGANIZATIONDPNR Legal Counsel
ORGANIZATIONthe Notice of Failure to
ORGANIZATIONthe Two Hundred Ten Thousand Dollar
ORGANIZATIONMARJORIE WHALEN
PERSONV.I. Bar Nos
ORGANIZATION