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ed. The Unauthorized and Unlass ful Elfin 16. On October 28, 2016, three (3) 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
e island known as Great St. James, located within the U.S. Virgin Islands, which is the site of activity in issue. 7. In April of 2016, DPNR issued Notice of Violation identified as NOVA-04-16-STT ("Notice of Violation") to GSJ seeking an assessment of Two Hundred Eighty Thousand Dollars ($280,000.00) for what DPN
nded. The Unauthorized and Unlawful Entry 16. On October 28, 2016, three (3) DPNR representatives, including an armed enforcement officer, Officer Mercer, Jean-Pierre Oriol, Director of Coastal Zone EFTA00583143 GS!, LLC v. DPNR et al. Civil No. 12017 Complaint Page 4 Management, and Attorney M
e island known as Great St. James, located within the U.S. Virgin Islands, which is the site of activity in issue. 7. In April of 2016, DPNR issued Notice of Violation identified as NOVA-04-16-STT ("Notice of Violation") to GSJ seeking an exorbitant, unprecedented, and unjustified assessment of Two Hundred Eighty
ll founded. The Unlawful Entry and Search 24. On October 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 EFTA00
ithin the U.S. Virgin Islands and known as the island of Great St. James, which is the site of activity in issue. 15. In April of 2016, DPNR issued Notice of Violation identified as NOVA-04-16-STT ("Notice of Violation") to GSJ seeking an assessment of Two Hundred Eighty Thousand Dollars ($280,000.00) for what DPN
nded. The Unauthorized and Unlawful Entry 16. On October 28, 2016, three (3) DPNR representatives, including an armed enforcement officer, Officer Mercer, Jean-Pierre Oriol, Director of Coastal Zone EFTA00583187 GS!, LLC v. DPNR et al. Civil No. 12017 Complaint Page 4 Management, and Attorney M
e island known as Great St. James, located within the U.S. Virgin Islands, which is the site of activity in issue. 7. In April of 2016, DPNR issued Notice of Violation identified as NOVA-04-16-STT ("Notice of Violation") to GSJ seeking an assessment of Two Hundred Eighty Thousand Dollars ($280,000.00) for what DPN
Entities connected to both Mercer and Notice of Violation

Woody Allen
PERSON
U.S. Virgin Islands
LOCATION
Sarah Ferguson
PERSON
James Baker
PERSONERIKA A. KELLERHALS
PERSON
Michael Barker
PERSON
Red Hook
LOCATION
Jean-Pierre Oriol
PERSON
Emblematic
PERSONOfficial Capacity
ORGANIZATIONPARTIES & JURISDICTION
ORGANIZATIONDPNR Legal Counsel
ORGANIZATIONthe Notice of Failure to
ORGANIZATIONthe Two Hundred Ten Thousand Dollar
ORGANIZATIONMARJORIE WHALEN
PERSONV.I.C.
ORGANIZATIONV.I. Bar Nos
ORGANIZATION
Great St. James
ORGANIZATIONDawn Henry
PERSONthe Board of Land Use Appeals
ORGANIZATION