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l of record on January 23, 2020 to: CHRISTOPHER ALLEN KROBLIN, ESQ. ANDREW W. HEYMANN, ESQ., WILLIAM
ed in carrying out, facilitating and concealing Epstein's crimes, hence Little St. James became an instrumentality of those crimes. 25. Defendant, Great St. Jim, LLC, is a limited liability company established and organized under the laws of the Virgin Islands. Great St. Jim, LLC was organized on October 26,
s president of Poplar, Inc. and expressly authorizes the incorporators to conduct "transactions related to permitting matters submitted on behalf of Great St. Jim, LLC." 30. Poplar, Inc. is listed as the signatory for the 2017 Annual Report for Great St. Jim, LLC, and the signature appears to be Epstein's. T
h 8, 2017 ERIKA A. KELLERHALS, ESQ. CHRISTOPHER ALLEN KROBLIN, ESQ. MARJORIE WHALEN, ESQ. V.I. Bar No
t the Department of Planning and Natural Resources and Commissioner Dawn Henry, states 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 Depa
, DPNR entered onto the premises of Great St. James and traversed the entire island without restriction, allegedly to conduct a "site inspection" of Great St. James, and verbally instructed workers to cease and desist from further activity on Great St. James. 19. This unauthorized entry and search was particula
h 8, 2017 ERIKA A. KELLERHALS, ESQ. CHRISTOPHER ALLEN KROBLIN, ESQ. MARJORIE WHALEN, ESQ. V.I. Bar No
t the Department of Planning and Natural Resources and Commissioner Dawn Henry, states 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 Depa
sment of Two Hundred Eighty Thousand Dollars ($280,000.00) for what DPNR alleged were violations of the Coastal Zone Management Act on the island of Great St. James. [EXHIBIT A] 8. GSJ vehemently contested both the alleged violations and the outrageous assessment as unjustified and well outside the scope of DPN
412, 2017 ERIKA A. KELLERHALS, ESQ. CHRISTOPHER ALLEN KROBLIN, ESQ. MARJORIE WHALEN, ESQ. V.I. Bar No
t the Department of Planning and Natural Resources and Commissioner Dawn Henry, states 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 Depa
el for DPNR made no attempt whatsoever to contact the undersigned legal counsel for prior approval or to notify GSJ before the unauthorized entry on Great St. James, the communication with GSJ personnel without permission, and the unlawful search. 23. By refusing to comply with the conditions of the permit and
ched photographs. Very truly yours, Christopher Allen Kroblin EFTA00800121 EFTA00800122 EFTA008001
e in receipt of the Cease and Desist Notice dated January 14, 2019 and have communicated with our client regarding the same. Please be advised that Great St. Jim is currently undertaking emergency repairs to its septic system which we believe does not require a permit due to exigent circumstances. Great St.
422, 2017- ERIKA A. KELLERHALS, ESQ. CHRISTOPHER ALLEN KROBLIN, ESQ. MARJORIE WHALEN, ESQ. V.I. Bar No
t the Department of Planning and Natural Resources and Commissioner Dawn Henry, states 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 Depa
Entities connected to both Woody Allen and Great St. James

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Marc Rich
PERSONDarren Indyke
PERSON
Prince Andrew
PERSON
Richard Kahn
PERSON
George Mitchell
PERSON
Boris Nikolic
PERSON
George W. Bush
PERSON
Prince Charles
PERSON
Ghislaine Maxwell
PERSON
Lawrence Krauss
PERSON
Larry Summers
PERSON
Joi Ito
PERSON
Jes Staley
PERSON
United States
LOCATIONLarry Visoski
PERSON
Martin Nowak
PERSON
David Mitchell
PERSON
Kathryn Ruemmler
PERSON