e hurricanes, it provided the completed information by hand delivery on February 8, 2018. During our meeting, you stated that DPNR sent a letter to Great St. Jim in April 2018 regarding the insufficiency of the permit applications. However, this is completely at odds with our review of the matter and neither

ng as it was only for the limited purpose of inspecting and ascertaining compliance at the areas of permitted sites with the terms and conditions of Great St. Jim's coastal zone permits. In other words, we certainly would not object to your coming to GSJ to review compliance with the permits that were granted, b

existing caretaker's cottage as well as the construction of additional living space adjacent to the cottage. As discussed with you at the meeting, Great St. Jim submitted two minor permit applications to your office on July 14, 2017. On August 23, 2017, we received a notification of deficiency from J.P. Orio

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

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

§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

e hurricanes, it provided the completed information by hand delivery on February 8, 2018. During our meeting, you stated that DPNR sent a letter to Great St. Jim in April 2018 regarding the insufficiency of the permit applications. However, this is completely at odds with our review of the matter. In fact, in

ng as it was only for the limited purpose of inspecting and ascertaining compliance at the areas of permitted sites with the terms and conditions of Great St. Jim's coastal zone permits. In other words, we certainly would not object to your coming to GSJ to review compliance with the permits that were granted, b

existing caretaker's cottage as well as the construction of additional living space adjacent to the cottage. As discussed with you at the meeting, Great St. Jim submitted two minor permit applications to your office on July 14, 2017. On August 23, 2017, we received a notification of deficiency from J.P. Orio

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

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

existing caretaker's cottage as well as the construction of additional living space adjacent to the cottage. As discussed with you at the meeting, Great St. Jim submitted two (2) minor permit applications to your office on July 14, 2017. On August 23, 2017, we received a notification of deficiency from J.P.

y on February 8, 2018. EFTA00794163 Letter to Y. Norman February 13, 2019 Page 2 of 4 During our meeting, you stated that DPNR sent a letter to Great St. Jim in April 2018 regarding the insufficiency of the permit applications. However, this is completely at odds with our review of the matter and neither

ng as it was only for the limited purpose of inspecting and ascertaining compliance at the areas of permitted sites with the terms and conditions of Great St. Jim's coastal zone permits. In other words, we certainly would not object to your coming to GSJ to review compliance with the permits that were granted, b

ed in carrying out, facilitating and concealing Epstein's crimes, hence Little St. James became an instrumentality of those crimes. 28. Defendant, Great St. Jim, LLC, is a limited liability company established and organized under the laws of the Virgin Islands. Great St. Jim, LLC was organized on October 26,

s president of Poplar, Inc. and expressly authorizes the incorporators to conduct "transactions related to permitting matters submitted on behalf of Great St. Jim, LLC." 32. Poplar, Inc. is listed as the signatory for the 2017 Annual Report for Great St. Jim, LLC, and the signature appears to be Epstein's. T

ed in carrying out, facilitating and concealing Epstein's crimes, hence Little St. James became an instrumentality of those crimes. 25. Defendant, Great St. Jim, LLC, is a limited liability company established and organized under the laws of the Virgin Islands. Great St. Jim, LLC was organized on October 26,

s president of Poplar, Inc. and expressly authorizes the incorporators to conduct "transactions related to permitting matters submitted on behalf of Great St. Jim, LLC." 30. Poplar, Inc. is listed as the signatory for the 2017 Annual Report for Great St. Jim, LLC, and the signature appears to be Epstein's. T

s president of Poplar, Inc. and expressly authorizes the incorporators to conduct "transactions related to permitting matters submitted on behalf of Great St. Jim, LLC." 30. Poplar, Inc. is listed as the signatory for the 2017 Annual Report for Great St. Jim, LLC, and the signature appears to be Epstein's. T

ed in carrying out, facilitating and concealing Epstein's crimes, hence Little St. James became an instrumentality of those crimes. 25. Defendant, Great St. Jim, LLC, is a limited liability company established and organized under the laws of the Virgin Islands. Great St. Jim, LLC was organized on October 26,

, 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

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

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

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

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

s president of Poplar, Inc. and expressly authorizes the incorporators to conduct "transactions related to permitting matters submitted on behalf of Great St. Jim, LLC." 30. Poplar, Inc. is listed as the signatory for the 2017 Annual Report for Great St. Jim, LLC, and the signature appears to be Epstein's. T

ed in carrying out, facilitating and concealing Epstein's crimes, hence Little St. James became an instrumentality of those crimes. 25. Defendant, Great St. Jim, LLC, is a limited liability company established and organized under the laws of the Virgin Islands. Great St. Jim, LLC was organized on October 26,

ed in carrying out, facilitating and concealing Epstein's crimes, hence Little St. James became an instrumentality of those crimes. 25. Defendant, Great St. Jim, LLC, is a limited liability company established and organized under the laws of the Virgin Islands. Great St. Jim, LLC was organized on October 26,

s president of Poplar, Inc. and expressly authorizes the incorporators to conduct "transactions related to permitting matters submitted on behalf of Great St. Jim, LLC." 30. Poplar, Inc. is listed as the signatory for the 2017 Annual Report for Great St. Jim, LLC, and the signature appears to be Epstein's. T

s president of Poplar, Inc. and expressly authorizes the incorporators to conduct "transactions related to permitting matters submitted on behalf of Great St. Jim, LLC." 32. Poplar, Inc. is listed as the signatory for the 2017 Annual Report for Great St. Jim, LLC, and the signature appears to be Epstein's. T

ed in carrying out, facilitating and concealing Epstein's crimes, hence Little St. James became an instrumentality of those crimes. 28. Defendant, Great St. Jim, LLC, is a limited liability company established and organized under the laws of the Virgin Islands. Great St. Jim, LLC was organized on October 26,

ng due diligence for the purchaser I assumed that that damage was probably associated with bringing supplies to work on the cottages. The new owner Great St. Jim, LLC was told by Kjear's representative that all permits were in order. And the applicant does have a CZM permit in good standing on the dock in it

bay is not suitable for barges. We are unaware of any discussion or correspondence with the previous owner about removing the boats on the dock. Great St. Jim, LLC would like to make the dock safe for continued access use to the island at this time and to install the RO intake line. The applicant is curren

ed in carrying out, facilitating and concealing Epstein's crimes, hence Little St. James became an instrumentality of those crimes. 27. Defendant, Great St. Jim, LLC, is a limited liability company established and organized under the laws of the Virgin Islands. Great St. Jim, LLC was organized on October 26,

s president of Poplar, Inc. and expressly authorizes the incorporators to conduct "transactions related to permitting matters submitted on behalf of Great St. Jim. LLC." 32. Poplar, Inc. is listed as the signatory for the 2017 Annual Report for Great St. Jim, LLC, and the signature appears to be Epstein's. T

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

rhals Ferguson Kroblin PLLC 9053 Estate Thomas, Suite 101 St. Thomas, Virgin Islands 00802 SUBJECT: Major CZM Permit Application No. CZT-1-18(W) Great St. Jim, LLC St Thomas, Virgin Islands Dear Ms. Kellerhals: Your application for the above-referenced CZM permit has been reviewed and found to be INCOMP

rovide document showing that Epstein is an authorized signatory for Poplar, Inc. E. Certificates of Good Standing are required. Please provide for Great St. Jim, LLC & Poplar, Inc. F. Property tax clearance letter submitted are all dated Nov. 14, 2016. We need letters dated 2017 as verification that the pr

rt Terminal Building 2nd Floor St. Thomas, VI 00802 Dawn.FienOtiparrigor Re: Great St. James Sargassum Issue Dear Attorney Henry: On behalf of Great St. Jim, LLC, we are requesting permission from your agency to utilize a mini excavator and trackhoe to remove significant amounts of sargassum which have b

rmission from your agency to utilize a mini excavator and trackhoe to remove significant amounts of sargassum which have blanketed the shorelines of Great St. James. The work will be undertaken by employees of Great St. Jim, LLC and we anticipate that it will be completed in two (2) weeks. We ask that you expedi

c Survey, Historic Artifact Locations Tropical Marine, Red Hook, St Thomas, VI — Carlos Ruan/Tropical Marina - Hydrographic Survey, Dock Permitting Great St James & Little St James Islands, VI —Great St Jim, LLC — Hydrographic Surveys, Wetland Locations, Dock & Environmental Permitting Greenside Properties, Inc,

ned so that barges can approach and land on the end of the dock while vessels can dock along the "L". After the hurricane Irma in 2017 the owner of the Great St. James assisted many of his employees and their families who had lost their homes and housed people on the island. In order to bring in emergency supplies