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ERS TESTAMENTARY COME NOW Petitioners DARREN K INDYKE and RICHARD D. KAHN, Executors of the Estate of Jeffrey E. Epstein, by and through KELLERHALS FERGUSON KROBLIN PLLC, and petition this Honorable Court to grant the instant petition pursuant to V.I. CODE ANN. tit. 15, 161 and Rule 3 of the Virgin Isla
l and territorial law and enforcement authorities. The Department of Planning and Natural Resources ("DPNR") regulates and monitors construction in the Coastal Zone to protect, maintain and manage the precious natural resources of the Virgin Islands. Under its authority, DPNR repeatedly issued citations and asse
Epstein Erika A. Kellerhals Member Kellerhals Ferguson Kroblin PLLC 9100 Port of Sale Mall Suite 15 St
location which has minimal impact and will not require mitigation. The Environmental Assessment Report will act as the main reference document for the Coastal Zone Management Permit application, the U.S. ACOE permit application, and the Water Quality Certificate and for any other approvals which may be require
and through its undersigned counsel, ICELLERHALs FERGUSON KROBLIN PLLC, and for its Complaint against the D
red Ten Thousand Dollar ($210,000) assessment against GSJ based on legally and factually deficient claims against GSJ purportedly for violations of the Coastal Zone Management Act (the "Act") on the large private single-family residence known as Great St. James. Such an assessment, of a magnitude never before i
24, 2016 Erika A. Kellerhals Member Kellerhals Ferguson Kroblin PLLC 9100 Port of Sale Mall Suite 15 St
mits required. We know that the dock extension will impact seagrass. The Environmental Assessment Report will act as the main reference document for the Coastal Zone Management Permit application, the U.S. ACOE permit application, and the Water Quality Certificate and for any other approvals which may be require
Epstein Erika A. Kellerhals Member Kellerhals Ferguson Kroblin PLLC 9100 Port of Sale Mall Suite 15 St
k location which has minimal impact and will not require mitigation. The Environmental Assessment Report will act as the main reference document for the Coastal Zone Management Permit application, the U.S. ACOE permit application, and the Water Quality Certificate and for any other approvals which may be require
18, 2016 Erika A. Kellerhals Member Kellerhals Ferguson Kroblin PLLC 9100 Port of Sale Mall Suite 15 St
will be critical in determining permit times and permits required. The Environmental Assessment Report will act as the main reference document for the Coastal Zone Management Permit application, the U.S. ACOE permit application, and the Water Quality Certificate and for any other approvals which may be require
Entities connected to both Sarah Ferguson and the Coastal Zone

Jeffrey Epstein
PERSONErika Kellerhals
PERSONFerguson Kroblin
PERSONDarren Indyke
PERSON
Richard Kahn
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
George W. Bush
PERSON
U.S. Virgin Islands
LOCATION
Bill Clinton
PERSON
Woody Allen
PERSON
Prince Charles
PERSON
Paul Ryan
PERSON
Stephen Hawking
PERSON
New York
LOCATION
Samantha Power
PERSON
Les Wexner
PERSONMaria Farmer
PERSON
JPMorgan Chase
ORGANIZATION
Jes Staley
PERSON