Epstein Secrets

and alleges as follows: PARTIES & JURISDICTION 1. Plaintiff Great St. Jim, LLC ("GSJ") is a limited liability company organized under the laws of the U.S. Virgin Islands. 2. Upon information and belief, Defendant the Department of Planning and Natural Resources ("DPNR") is an instrumentality of the Government of the

t, Defendants unilaterally and arbitrarily imposed only a ten (10) day cure period, which included five (5) days of weekends and a legal federal and Virgin Islands holiday. 7. All of this appears to have been a deliberate effort to ensure that it would be impossible for GSJ to cure DPNR's list of inadequately

******************* GREAT ST. JIM, LLC, ) ) Plaintiff, ) ) v. ) ) DEPARTMENT OF PLANNING AND ) NATURAL RESOURCES and DAWN HENRY ) In Her Official Capacity as Commissioner of the ) Department of Planning and Natural Resources, ) ) Defendants. ) ) CIVIL NO. 12017 COMPLAINT COMES NOW Plaintiff G

and alleges as follows: PARTIES & JURISDICTION 1. Plaintiff Great St. Jim, LLC ("GSJ") is a limited liability company organized under the laws of the U.S. Virgin Islands. 2. Upon information and belief, Defendant the Department of Planning and Natural Resources ("DPNR") is an instrumentality of the Government of the

******************* GREAT ST. JIM, LLC, ) ) Plaintiff, ) ) v. ) ) DEPARTMENT OF PLANNING AND ) NATURAL RESOURCES and DAWN HENRY ) In Her Official Capacity as Commissioner of the ) Department of Planning and Natural Resources, ) ) Defendants. ) ) CIVIL NO. 12017 COMPLAINT COMES NOW Plaintiff G

and alleges as follows: PARTIES & JURISDICTION 1. Plaintiff Great St. Jim, LLC ("GSJ") is a limited liability company organized under the laws of the U.S. Virgin Islands. 2. Upon information and belief, Defendant the Department of Planning and Natural Resources ("DPNR") is an instrumentality of the Government of the

******************* GREAT ST. JIM, LLC, ) ) Plaintiff, ) ) v. ) ) DEPARTMENT OF PLANNING AND ) NATURAL RESOURCES and DAWN HENRY ) In Her Official Capacity as Commissioner of the ) Department of Planning and Natural Resources, ) ) Defendants. ) ) CIVIL NO. 12017 COMPLAINT COMES NOW Plaintiff G

and alleges as follows: PARTIES & JURISDICTION 1. Plaintiff Great St. Jim, LLC ("GSJ") is a limited liability company organized under the laws of the U.S. Virgin Islands. 2. Upon information and belief, Defendant the Department of Planning and Natural Resources ("DPNR") is an instrumentality of the Government of the

******************* GREAT ST. JIM, LLC, ) ) Plaintiff, ) ) v. ) ) DEPARTMENT OF PLANNING AND ) NATURAL RESOURCES and DAWN HENRY ) In Her Official Capacity as Commissioner of the ) Department of Planning and Natural Resources, ) ) Defendants. ) ) CIVIL NO. 12017 COMPLAINT COMES NOW Plaintiff G