) ) Defendants. ) ) CIVIL NO. 12017 COMPLAINT COMES NOW Plaintiff Great St. Jim, LLC, by and through its undersigned counsel, ICELLERHALs FERGUSON KROBLIN PLLC, and for its Complaint against the Department of Planning and Natural Resources and Commissioner Dawn Henry, states and alleges as follows: PARTIES

23, 2020 to: CHRISTOPHER ALLEN KROBLIN, ESQ. ANDREW W. HEYMANN, ESQ., WILLIAM BLUM, ESQ. SHAR1 D'ANDRADE, ESQ. MARJORIE WHALEN, ESQ. KELLERHALS FERGUSON KROBLIN PLLC Royal Palm Professional Building 9053 Estate Thomas, Suite 101 St. Thomas, V.I. 00802-3602 ele Email: 8 EFTA00074751 IN THE SUPERIOR COURT OF