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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
e a cure period of a reasonable 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. EF
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
e a cure period of a reasonable 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. EF
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
ent of the contractually 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 co
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
e a cure period of a reasonable 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. EF
Entities connected to both Emblematic and the Notice of Failure to

U.S. Virgin Islands
LOCATION
Woody Allen
PERSON
James Baker
PERSON
Michael Barker
PERSON
Sarah Ferguson
PERSONMercer
PERSON
Red Hook
LOCATION
Jean-Pierre Oriol
PERSONthe Board of Land Use Appeals
ORGANIZATIONOfficial Capacity
ORGANIZATIONPARTIES & JURISDICTION
ORGANIZATIONNotice of Violation
ORGANIZATIONDPNR Legal Counsel
ORGANIZATIONthe Two Hundred Ten Thousand Dollar
ORGANIZATIONMARJORIE WHALEN
PERSONV.I.C.
ORGANIZATIONV.I. Bar Nos
ORGANIZATION
Great St. James
ORGANIZATIONERIKA A. KELLERHALS
PERSONDawn Henry
PERSON