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of Coastal Zone Management, and Attorney Michele Baker, DPNR Legal Counsel, entered upon Great St. Jame
an arbitrary and unreasonably short cure period, all in clear violation of DPNR's obligations and GSJ's rights under the Settlement Agreement. 24. Emblematic, though not an exhaustive list, of alleged violations DPNR improperly asserted against GSJ in the Notice to Cure were the following: a. An alleged
mplaint Page 4 Management, and Attorney Michele Baker, DPNR Legal Counsel, entered upon Great St. Jame
an arbitrary and unreasonably short cure period, all in clear violation of DPNR's obligations and GSJ's rights under the Settlement Agreement. 24. Emblematic, though not an exhaustive list, of alleged violations DPNR improperly asserted against GSJ in the Notice to Cure were the following: a. Alleged vio
rre Oriol, Director of CZM, and Attorney Michele Baker, DPNR Legal Counsel, entered upon Great St. James
an arbitrary and unreasonably short cure period, all in clear violation of DPNR's obligations and GSJ's rights under the Settlement Agreement. 35. Emblematic, though not an exhaustive list, of alleged violations DPNR improperly asserted against GSJ in the Notice to Cure were the following: a. An alleged
mplaint Page 4 Management, and Attorney Michele Baker, DPNR Legal Counsel, entered upon Great St. Jame
an arbitrary and unreasonably short cure period, all in clear violation of DPNR's obligations and GSJ's rights under the Settlement Agreement. 28. Emblematic, though not an exhaustive list, of alleged violations DPNR improperly asserted against GSJ in the Notice to Cure were the following: a. An alleged
Entities connected to both James Baker and Emblematic

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Woody Allen
PERSON
Marc Rich
PERSON
Alan Dershowitz
PERSONDarren Indyke
PERSON
Sarah Ferguson
PERSON
Michael Barker
PERSON
U.S. Virgin Islands
LOCATION
Jean-Pierre Oriol
PERSON
Great St. James
ORGANIZATIONMercer
PERSONDawn Henry
PERSONV.I.C.
ORGANIZATIONERIKA A. KELLERHALS
PERSONMARJORIE WHALEN
PERSONV.I. Bar Nos
ORGANIZATIONOfficial Capacity
ORGANIZATIONPARTIES & JURISDICTION
ORGANIZATIONNotice of Violation
ORGANIZATION