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011-0003, 2012 WL 8123137, at •3 (V.1. Sept. 12, 2012). When Kjaer owned both Parcel A and Parcel II, any use of parcel 11 as a staging ground for Parcel A was simply a landowner using his land. Kjacr was not using an easement over his own land. By operation of law there was no easement when the Kjaers
ELIEF, PRIVATE NUISANCE, DIMINUTION OF VALUE, UNJUST ENRICHMENT & ACCOUNTING MOTION TO DISMISS THE FIRST AMENDED COMPLAINT COMES NOW, Defendants Christian Kjaer ("Kjaer") in personam and Parcel II, Estate Nazareth, St. Thomas, U.S. Virgin Islands in rem ("Parcel 11") (collectively "Defendants"), by and thro
lers-at-the-time-ef-exemitien-of--thisagreemeat. 1.1 EFTA00582979 ARTICLE 2 PURCHASE PRICE 2.1 Amount. The purchase price for CK's interest in Parcel A of the the-entire Property and the Stock Interest(the "Purchase Price") is and shall be Twenty Two Million Five Hundred Thousand and No/100 U.S. D
which shall not be unreasonably withheld or delayed. [Signature pages follow) 12 EFTA00582990 EXECUTED by Seller on the day of 2015. SELLER: Christian Kjaer, individually By: GS.I Properties, Corp. By: Name: Title: 13 EFTA00582991 EXECUTED by Purchaser on the day of , 2015. PURCHASER: Great
rovements located thereon (such land, buildings and improvements, the "Property"); B. CK is the permittee of a submerged land permit, for a dock on Parcel A, designated and more particularly described in Exhibit B attached hereto (the "Permit"), ; and C. Subject to the terms of this Agreement as more f
t, which shall not be unreasonably withheld or delayed. [Signature pages follow] EFTA00583029 EXECUTED by Seller on the day of 2016. SELLER: Christian Kjaer, individually By: GS.I Properties, Corp. By: Name: Title: 12 EFTA00583030 EXECUTED by Purchaser on the day of , 2016. PURCHASER: Great
aterial respects. For purposes of this Agreement, "to Sellers' knowledge" shall mean the actual knowledge of Christian Kjaer, the owner of record of Parcel A and the sole shareholder of the Corporation, who is the most knowledgeable person with regard to the Corporation and the Property. 7.3 REPRESENTA
l be true, complete and correct in all material respects. For purposes of this Agreement, "to Sellers' knowledge" shall mean the actual knowledge of Christian Kjaer, the owner of record of Parcel A and the sole shareholder of the Corporation, who is the most knowledgeable person with regard to the Corporation an
Entities connected to both Parcel A and Christian Kjaer

U.S. Virgin Islands
LOCATION
Kjaer
PERSONErika Kellerhals
PERSON
Sarah Ferguson
PERSON
Lausanne
LOCATION
Great St. James
ORGANIZATIONthe Property free of the same
ORGANIZATIONInternational Arbitration Rules
ORGANIZATIONApril Newland
PERSONGSJ Properties, Corp.
ORGANIZATIONVirgin Islands Limited Liability Company
ORGANIZATIONPepper Hamilton LLP
ORGANIZATION
Switzerland
LOCATION
Philadelphia
LOCATIONJames T. Giles
PERSONCommissions
ORGANIZATIONALTA Owner's
ORGANIZATIONthe Property (Parcel A
ORGANIZATIONthe Territory of the U.S Virgin Islands
LOCATIONthe American Arbitration Association
ORGANIZATION