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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
e a cure period of a reasonable duration after proper and adequate notice of any alleged violation to be cured. I On January 17, 2017, GSJ appealed the Notice of Failure to the Board of Land Use Appeals. This action, however, raises entirely separate causes of action derived from the Settlement Agreement provisions. EF
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
e a cure period of a reasonable duration after proper and adequate notice of any alleged violation to be cured. I On January 17, 2017, GSJ appealed the Notice of Failure to the Board of Land Use Appeals. This action, however, raises entirely separate causes of action derived from the Settlement Agreement provisions. EF
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
ent of the contractually required notice or a duration for the contractually required cure period, the Settlement On January 17, 2017, GSJ appealed the Notice of Failure to the Board of Land Use Appeals. This-aetienThe present Complaint however, raises entirely separate causes of action derived from the breach of the co
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
e a cure period of a reasonable duration after proper and adequate notice of any alleged violation to be cured. I On January 17, 2017, GSJ appealed the Notice of Failure to the Board of Land Use Appeals. This action, however, raises entirely separate causes of action derived from the Settlement Agreement provisions. EF
Entities connected to both Michael Barker and the Notice of Failure to

James Baker
PERSON
Woody Allen
PERSON
Sarah Ferguson
PERSON
Jean-Pierre Oriol
PERSON
Great St. James
ORGANIZATION
U.S. Virgin Islands
LOCATIONV.I.C.
ORGANIZATIONDawn Henry
PERSONERIKA A. KELLERHALS
PERSONMercer
PERSON
Red Hook
LOCATIONMARJORIE WHALEN
PERSONV.I. Bar Nos
ORGANIZATION
Emblematic
PERSONOfficial Capacity
ORGANIZATIONPARTIES & JURISDICTION
ORGANIZATIONNotice of Violation
ORGANIZATIONDPNR Legal Counsel
ORGANIZATIONthe Two Hundred Ten Thousand Dollar
ORGANIZATIONthe Board of Land Use Appeals
ORGANIZATION