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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
atives, including an armed enforcement officer, Officer Mercer, Jean-Pierre Oriol, Director of Coastal Zone Management, and Attorney Michele Baker, DPNR Legal Counsel, entered upon Great St. James without prior notice to or approval from GSJ, and outside of project working hours and demanded access to the entire
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
Oriol, Director of Coastal Zone EFTA00583143 GS!, LLC v. DPNR et al. Civil No. 12017 Complaint Page 4 Management, and Attorney Michele Baker, DPNR Legal Counsel, entered upon Great St. James without prior notice to or approval from GSJ, and outside of project working hours and demanded access to the entire
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
e (3) DPNR representatives, including an armed enforcement officer, Officer Mercer, Jean-Pierre Oriol, Director of CZM, and Attorney Michele Baker, DPNR Legal Counsel, entered upon Great St. James without prior notice to or EFTA00583162 GSI LLC v. DPNR et al. Civil No. 12017 Complaint Page 6 permission from
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
Oriol, Director of Coastal Zone EFTA00583187 GS!, LLC v. DPNR et al. Civil No. 12017 Complaint Page 4 Management, and Attorney Michele Baker, DPNR Legal Counsel, entered upon Great St. James without prior notice to or approval from GSJ, or any legal authority to do so. 17. DPNR previously issued a minor Co
Entities connected to both Notice of Violation and DPNR Legal Counsel

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
ORGANIZATION
Emblematic
PERSONOfficial Capacity
ORGANIZATIONPARTIES & JURISDICTION
ORGANIZATIONthe Notice of Failure to
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