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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
ations for permits submitted by GSJ, asserted by Defendants as being justified based on the unresolved Notice of Failure to Cure and non-payment of the Two Hundred Ten Thousand Dollar ($210,000.00) assessment imposed therein, is also outside the scope of and an unlawful exercise of Defendants' authority, and directing DPNR to con
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
ations for permits submitted by GSJ, asserted by Defendants as being justified based on the unresolved Notice of Failure to Cure and non-payment of the Two Hundred Ten Thousand Dollar ($210,000.00) assessment imposed therein, is also outside the scope of and an unlawful exercise of Defendants' EFTA00583153 GS!, LLC v. DPNR et a
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
ations for permits submitted by GSJ, asserted by Defendants as being justified based on the unresolved Notice of Failure to Cure and non-payment of the Two Hundred Ten Thousand Dollar ($210,000.00) assessment imposed therein, is also outside the scope of and an unlawful exercise of Defendants' authority, and directing DPNR to con
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
ations for permits submitted by GSJ, asserted by Defendants as being justified based on the unresolved Notice of Failure to Cure and non-payment of the Two Hundred Ten Thousand Dollar ($210,000.00) assessment imposed therein, is also outside the scope of and an unlawful exercise of Defendants' EFTA00583199 GSI LLC v. DPNR et al
Entities connected to both Mercer and the Two Hundred Ten Thousand Dollar

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
ORGANIZATIONNotice of Violation
ORGANIZATIONDPNR Legal Counsel
ORGANIZATIONthe Notice of Failure to
ORGANIZATIONMARJORIE WHALEN
PERSONV.I.C.
ORGANIZATIONV.I. Bar Nos
ORGANIZATION
Great St. James
ORGANIZATIONDawn Henry
PERSONthe Board of Land Use Appeals
ORGANIZATION