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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 notice to or approval from GSJ, and outside of project working hours and demanded a
DPNR caused a written cease and desist order, =-02-16-STT, dated October 28, 2016, to be served on counsel for GSJ via email and delivered to GSJ's Red Hook office on October 31, 2016 (the "Cease and Desist Order"). [EXHIBIT CI EFTA00583130 GS!, LLC v. DPNR et al. Civil No. / 2017 Complaint Page 5
owner was not on the island and that the GSJ personnel present had no authority to grant access to the island, and directed DPNR to GSJ's office in Red Hook. 18. Nevertheless, over the protests of GSJ personnel, and lacking any legal authority whatsoever, DPNR entered onto the premises of Great St. Jame
r, Jean-Pierre Oriol, Director of Coastal Zone EFTA00583143 GS!, LLC v. DPNR et al. Civil No. 12017 Complaint Page 4 Management, and Attorney Michele Baker, DPNR Legal Counsel, entered upon Great St. James without prior notice to or approval from GSJ, and outside of project working hours and demanded a
2016, to EFTA00583144 GS!, LLC v. DPNR et aL Civil No. / 2017 Complaint Page 5 be served on counsel for GSJ via email and delivered to GSJ's Red Hook office on October 31, 2016 (the "Cease and Desist Order"). [EXHIBIT CI Erroneous Notice to Cure & the Arbitrary and Unreasonable Cure Period 21. O
owner was not on the island and that the GSJ personnel present had no authority to grant access to the island, and directed DPNR to GSJ's office in Red Hook. 18. Nevertheless, over the protests of GSJ personnel, and lacking any legal authority whatsoever, DPNR entered onto the premises of Great St. Jame
r 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 EFTA00583162 GSI LLC v. DPNR et al. Civil No. 12017 Complaint Pag
a written cease and desist order, M02-16-STT, dated October 28, 2016, that was to be served on counsel for GSJ via email and was delivered to GSJ's Red Hook office on October 31, 2016 (the "Cease and Desist Order"). [EXHIBIT D] Erroneous Notice to Cure & the Arbitrary and Unreasonable Cure Period 33. O
owner was not on the island and that the GSJ personnel present had no authority to grant access to the island, and directed DPNR to GSJ's office in Red Hook. 29. Nevertheless, over the protests of GSJ personnel, and lacking any legal grettedsground or right whatsoever, DPNR illegally entered onto the pre
r, Jean-Pierre Oriol, Director of Coastal Zone EFTA00583187 GS!, LLC v. DPNR et al. Civil No. 12017 Complaint Page 4 Management, and Attorney Michele Baker, DPNR Legal Counsel, entered upon Great St. James without prior notice to or approval from GSJ, or any legal authority to do so. 17. DPNR previous
written cease and desist order, IM-02-16-STT, dated October 28, 2016, that was to be served on counsel for GSJ via email and was delivered to GSJ's Red Hook office on October 31, 2016 (the "Cease and Desist Order"). [EXHIBIT DI Erroneous Notice to Cure & the Arbitrary and Unreasonable Cure Period EFTA0
owner was not on the island and that the GSJ personnel present had no authority to grant access to the island, and directed DPNR to GSJ's office in Red Hook. 21. Nevertheless, over the protests of GSJ personnel, and lacking any legal authority whatsoever, DPNR entered onto the premises of Great St. Jame
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