Epstein Secrets

ndberg Bay, Suite 61 Cyril E. King Airport Terminal Building. 2fid Floor St. Thomas. VI 00802 Re: Notice to Cure & NOVA-04-16-STT Dear Attorney Baker: I wanted to let you know that Great St. Jim, LLC is well underway in addressing the items set forth in the Notice to Cure, having completely remov

ior to the acquisition of Great St. James Island. The morrings were not installed by Great St Jim, LLC nor have they been nor are they maintained by Great St. Jim, LLC. The moorings are affixed to submerged land which is not part of Great St. James Island and not owned by Great St Jim, LLC. Although Great St.

ion I, Paragraphs 7A and 7C, respectively, of the Notice to Cure. Photographs of the completed work are attached for your reference. As you can see, Great St. Jim, LLC is doing everything it can to comply as quickly as possible with DPNR's directives in the Notice to Cure. In continuing work with regard to the

eat St Jim, LLC seeks clarification as to what specifically DPNR claims to be the violation involved in the item described in Paragraph 7B. Although Great St. Jim, LLC disagrees that the retaining wall constitutes a violation, we will be happy to remove it after receiving clarification as to what cure DPNR req

il E. King Airport Terminal Building 2nd Floor St. Thomas, VI 00802 Michele.Baker@dpnr.vi.gov Re: Notice to Cure & NOVA-04-16-STT Dear Attorney Baker: I wanted to let you know that Great St. Jim, LLC is well underway in addressing the items set forth in the Notice to Cure, having completely remov

e Settlement Agreement. These moorings were in place prior to Great St. Jim, LLC's acquisition of Great St. James Island. They were not installed by Great St. Jim, LLC nor have they been nor are they maintained by Great St. Jim, LLC. The moorings are affixed to submerged land which is not part of Great St. Ja

covering identified in Paragraphs 7A and C would have substantially mitigated any potential for soil erosion, blow off or runoff. In addition, had Great St. Jim, LLC elected to mitigate the potential for soil erosion, blow off and runoff at the site identified in Paragraph 7A by covering the area with a larg

§910(a)(1) is prime example of why further discussion and clarification is required before Great St Jim, LLC takes further action and DPNR declares Great St. Jim, LLC in default under the Settlement Agreement. These moorings were in place prior to Great St. Jim, LLC's acquisition of Great St. James Island. Th

l E. King Airport Terminal Building. 2nd Floor St. Thomas, VI 00802 Michele.Baker@dpnr.vi.gov Re: Notice to Cure & NOVA-04-16-STT Dear Attorney Baker: I wanted to follow up with you on some items regarding the Notice to Cure that we had intended to discuss during our meeting that was originally s

graph 7H of the Notice to Cure, were installed prior to Great St. Jim, LLC's acquisition of Great St. James Island and are not maintained or used by Great St. Jim, LLC. The four moorings are affixed to submerged land which is not part of Great St. James Island. That being said, we are happy to assist DPNR by

n on its removal. 7.H. Four moorings in the water. • The four moorings referred to in paragraph 7H of the Notice to Cure, were installed prior to Great St. Jim, LLC's acquisition of Great St. James Island and are not maintained or used by Great St. Jim, LLC. The four moorings are affixed to submerged land w

of Coastal Zone Management, and Attorney Michele Baker, DPNR Legal Counsel, entered upon Great St. Jame

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

mplaint Page 4 Management, and Attorney Michele Baker, DPNR Legal Counsel, entered upon Great St. Jame

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

mplaint Page 4 Management, and Attorney Michele Baker, DPNR Legal Counsel, entered upon Great St. Jame

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

Bay_RFP-15-001 ATN/Innovative/Choice Group Reno Baker Residence, Parcel 23 Estate Elizabeth Little St.

min. Baker Residence. Parcel 23 Estate Elizabeth 16-008 A001 Admin. 8 2 LIRE ST. JAMES POOLSIDE BUILDING 16-010 A001 Admin. 8 8 3 6 4 GreattSt James 16-011 A001 Admin 3 4 B 8 TOTALS 0 8 8 8 8 8 8 8 0 8 8 72 INVOICE TOTAL FOR SERVICES RENDERED: Signature Egli@ Date: Remitte

anagement 8100 Lindberg Bay, Suite 61 Cyril E. King Airport Terminal Building 2nd Floor St. Thomas, VI. 00802 Re: NOVA-04-16-STT Dear Attorney Baker: We have reviewed the Notice of Assessment of Civil Penalty, Order for Corrective Action and Notice of Opportunity for Hearing, dated November 4, 2

otice of Assessment of Civil Penalty, Order for Corrective Action and Notice of Opportunity for Hearing, dated November 4, 2016, and shall work with Great St. Jim, LLC to address DPNR's concerns regarding any and all issues claimed in paragraph seven (7) therein and to promptly cure any and all such issues in

OMMEN= Sent: Mo=day, November 7, 2016 4:42:45 PM To: Michele Baker Cc: =ean-Pierre Oriol; Kellerhals' Subject: N=VA-04.16-STT Good day Attorney Baker: Please see the attached corresp=ndence. Best regards, Sha=na Betz Legal Assistant ; 'Amy Claire Dempsey'; 'Erika =span style="font-size: 12pt;

an opportunity to discuss f=ctual inaccuracies relied upon in the Notice to Cure, which includes the re=oval of moorings that were not installed by Great St. Jim, LLC and were in =xistence prior to the purchase of the island, the demolition of a mov=able beach bar/cabana which DPNR Officer Rosa had notice of

rre Oriol, Director of CZM, and Attorney Michele Baker, DPNR Legal Counsel, entered upon Great St. James

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