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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
ations for permits submitted by GSJ, asserted by Defendants as being justified based on the unresolved Notice of Failure to Cure and non-payment of the Two Hundred Ten Thousand Dollar ($210,000.00) assessment imposed therein, is also outside the scope of and an unlawful exercise of Defendants' authority, and directing DPNR to con
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
ations for permits submitted by GSJ, asserted by Defendants as being justified based on the unresolved Notice of Failure to Cure and non-payment of the Two Hundred Ten Thousand Dollar ($210,000.00) assessment imposed therein, is also outside the scope of and an unlawful exercise of Defendants' EFTA00583153 GS!, LLC v. DPNR et a
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
ations for permits submitted by GSJ, asserted by Defendants as being justified based on the unresolved Notice of Failure to Cure and non-payment of the Two Hundred Ten Thousand Dollar ($210,000.00) assessment imposed therein, is also outside the scope of and an unlawful exercise of Defendants' authority, and directing DPNR to con
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
ations for permits submitted by GSJ, asserted by Defendants as being justified based on the unresolved Notice of Failure to Cure and non-payment of the Two Hundred Ten Thousand Dollar ($210,000.00) assessment imposed therein, is also outside the scope of and an unlawful exercise of Defendants' EFTA00583199 GSI LLC v. DPNR et al
Entities connected to both Dawn Henry and the Two Hundred Ten Thousand Dollar

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
ORGANIZATIONNotice of Violation
ORGANIZATIONDPNR Legal Counsel
ORGANIZATIONthe Notice of Failure to
ORGANIZATIONMercer
PERSONMARJORIE WHALEN
PERSONV.I.C.
ORGANIZATIONV.I. Bar Nos
ORGANIZATIONERIKA A. KELLERHALS
PERSONthe Board of Land Use Appeals
ORGANIZATION
Emblematic
PERSON