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rsigned 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 & JURISDICTION 1. Plaintiff Great St. Jim, LLC ("GSJ") is a limited liability company organized under the
e island known as Great St. James, located within the U.S. Virgin Islands, which is the site of activity in issue. 7. In April of 2016, DPNR issued Notice of Violation identified as NOVA-04-16-STT ("Notice of Violation") to GSJ seeking an assessment of Two Hundred Eighty Thousand Dollars ($280,000.00) for what DPN
rsigned 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 & JURISDICTION 1. Plaintiff Great St. Jim, LLC ("GSJ") is a limited liability company organized under the
e island known as Great St. James, located within the U.S. Virgin Islands, which is the site of activity in issue. 7. In April of 2016, DPNR issued Notice of Violation identified as NOVA-04-16-STT ("Notice of Violation") to GSJ seeking an exorbitant, unprecedented, and unjustified assessment of Two Hundred Eighty
rsigned 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 & JURISDICTION 1. Plaintiff Great St. Jim, LLC ("GSJ") is a limited liability company organized under the
ithin the U.S. Virgin Islands and known as the island of Great St. James, which is the site of activity in issue. 15. In April of 2016, DPNR issued Notice of Violation identified as NOVA-04-16-STT ("Notice of Violation") to GSJ seeking an assessment of Two Hundred Eighty Thousand Dollars ($280,000.00) for what DPN
rsigned 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 & JURISDICTION 1. Plaintiff Great St. Jim, LLC ("GSJ") is a limited liability company organized under the
e island known as Great St. James, located within the U.S. Virgin Islands, which is the site of activity in issue. 7. In April of 2016, DPNR issued Notice of Violation identified as NOVA-04-16-STT ("Notice of Violation") to GSJ seeking an assessment of Two Hundred Eighty Thousand Dollars ($280,000.00) for what DPN
Entities connected to both Dawn Henry and Notice of Violation

Sarah Ferguson
PERSON
Woody Allen
PERSON
Jean-Pierre Oriol
PERSON
James Baker
PERSON
U.S. Virgin Islands
LOCATION
Michael Barker
PERSON
Great St. James
ORGANIZATION
Red Hook
LOCATIONOfficial Capacity
ORGANIZATIONPARTIES & JURISDICTION
ORGANIZATIONDPNR Legal Counsel
ORGANIZATIONthe Notice of Failure to
ORGANIZATIONthe Two Hundred Ten Thousand Dollar
ORGANIZATIONMercer
PERSONMARJORIE WHALEN
PERSONV.I.C.
ORGANIZATIONV.I. Bar Nos
ORGANIZATIONERIKA A. KELLERHALS
PERSONthe Board of Land Use Appeals
ORGANIZATION
Emblematic
PERSON