Epstein Secrets

ofessional Building, 9053 Estate Thomas. Suite 101. St. Thomas, V i 00802 Telephone I Fax I www keilfercom November 17, 2016 Via Electronic Mail Michele Baker, Esq. Legal Counsel Division of Coastal Zone Management 8100 Lindberg Bay, Suite 61 Cyril E. King Airport Terminal Building. 2fid Floor St. Tho

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

e 101, St. Thomas, V.l. 00802 340.779.2564 Telephone I 1.888.316.9269 Fax I www.kellfer.com November 17, 2016 Via Hand Delivery & Electronic Mail Michele Baker, Esq. Legal Counsel Division of Coastal Zone Management 8100 Lindberg Bay, Suite 61 Cyril E. King Airport Terminal Building 2nd Floor St. Thoma

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

te 101. St. Thanes. V.1.00802 340.779.2564 Telephone I 1.888.316.9269 Fax I www.kellfer.com November 16, 2016 Via Hand Delivery & Electronic Mail Michele Baker, Esq. Legal Counsel Division of Coastal Zone Management 8100 Lindberg Bay, Suite 61 Cyril E. King Airport Terminal Building. 2nd Floor St. Thom

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

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

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

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

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

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

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

Royal Palms Professional Building. 9053 Estate Thomas, Suite 101, St. Thomas, V.I. 00802 I www.kellfer.com November 7, 2016 Via Electronic Mail < Michele Baker, Esq. Legal Counsel Division of Coastal Zone Management 8100 Lindberg Bay, Suite 61 Cyril E. King Airport Terminal Building 2nd Floor St. Thoma

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

From: Erika Kellerhals Sent: Friday, November 11, 2016 8:55 PM To: Michele Baker Cc: Jean-Pierre Oriol; Chris Kroblin Subject: Re: NOVA-04-16-STT Miche=e, Good afternoon. I apologize for not responding sooner, but our =ffice

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

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

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