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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
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
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
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
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
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
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
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 U.S. Virgin Islands and the Notice of Failure to

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