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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
ll founded. The Unlawful Entry and Search 24. On October 28, 2016, three (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 EFTA00
iter's com- petence and the victims truthfulness. In addition to mansions in Palm Beach and Manhat- tan, Epstein owns homes in New Mexico and the Virgin Islands. He's a frequent con- tributor to Democratic Party candidates. He also donated $30 million to Harvard in 2003. Former New York Gov. Eliot Spitze
Johnson. New York Post. New York N.Y.: Dec 28, 2003. pg. 012 Abstract (Document Summary) ANDRE BALAZS, 46. The ever-smiling hotelier - who owns The Mercer in Soho, Chateau Marmont and the Standard in L.A., the Raleigh in Miami, Sunset Beach on Shelter lasland, and a new place in St. Barts -just split
ogs of who visited Epstein's private island, records of a wiretap of Ghislalne Maxwell's phone, and documents related to Epstein's properties in the U.S. Virgin Islands. The files also contain physical evidence such as photographs, travel logs, and employee lists, as well as digital data stored on computers, storage
oto rejected the federal minimum of 15 years, citing the severity of his crimes and the erosion of public trust in law enforcement. Hoodline (07/17, Mercer) quoted a statement from FBI Assistant Director in Charge, Christopher G. Rala: "Christopher Terranova, a former NYPD officer, targeted and sexually
ogs of who visited Epstein's private island, records of a wiretap of Ghislalne Maxwell's phone, and documents related to Epstein's properties in the U.S. Virgin Islands. The files also contain physical evidence such as photographs, travel logs, and employee lists, as well as digital data stored on computers, storage
oto rejected the federal minimum of 15 years, citing the severity of his crimes and the erosion of public trust in law enforcement. Hoodline (07/17, Mercer) quoted a statement from FBI Assistant Director in Charge, Christopher G. Rala: "Christopher Terranova, a former NYPD officer, targeted and sexually
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
ed. The Unauthorized and Unlass ful Elfin 16. On October 28, 2016, three (3) DPNR representatives, 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
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
nded. The Unauthorized and Unlawful Entry 16. On October 28, 2016, three (3) DPNR representatives, including an armed enforcement officer, Officer Mercer, Jean-Pierre Oriol, Director of Coastal Zone EFTA00583143 GS!, LLC v. DPNR et al. Civil No. 12017 Complaint Page 4 Management, and Attorney M
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
nded. The Unauthorized and Unlawful Entry 16. On October 28, 2016, three (3) DPNR representatives, including an armed enforcement officer, Officer Mercer, Jean-Pierre Oriol, Director of Coastal Zone EFTA00583187 GS!, LLC v. DPNR et al. Civil No. 12017 Complaint Page 4 Management, and Attorney M
had sought his help in becoming a model. The lawsuit filed Thurs- day also alleges that Epstein has assaulted girls on his private island in the Virgin Islands. Herman declined to elaborate on that assertion. • larty_lcellerOpbposteom t, BANKRUPTCY • Save Your Home! You Ma y • Stop The Calls! • Elimin
ohnson. New York Post. New York, N.Y.: Dec 28, 2003. pg. 012 Abstract (Document Summary) ANDRE BALAZS, 46. The ever-smiling hotelier - who owns The Mercer in Soho, Chateau Marmont and the Standard in L.A., the Raleigh in Miami, Sunset Beach on Shelter lasland, and a new place in St. Barts -just split
Entities connected to both U.S. Virgin Islands and Mercer

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
New York
LOCATION
Les Wexner
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Bill Clinton
PERSON
Donald Trump
PERSONthe Southern District
LOCATION
Palm Beach
LOCATION
Department of Justice
ORGANIZATIONLeon Black
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Sarah Ferguson
PERSON
Virginia Giuffre
PERSON
Marc Rich
PERSON
Puerto Rico
LOCATION