EFTA00583158Set 9
2016-08-0422p6,313w
Islands.
2. Upon information and belief, Defendant the Department of Planning and Natural
Resources ("DPNR") is an instrumentality of the Government of the U.S. Virgin
Islands.
3. Defendant Dawn Henry ... Commissioner of Defendant DPNR.
4. This action arises out of Defendants violations of DPNR's obligations to GSJ under a
settlement agreement with GSJ signed by the Director of Coastal ... Defendant Commissioner Henry on August 4, 2016
(the "Settlement Agreement").
EFTA00583158
GS!, LLC v. DPNR et al. Civil No. / 2017
Complaint Page 2
5. Defendants violated the Settlement Agreement when
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583158.pdf
EFTA00583185Set 9
2016-08-0416p4,364w
Islands.
2. Upon information and belief, Defendant the Department of Planning and Natural
Resources ("DPNR") is an instrumentality of the Government of the U.S. Virgin
Islands.
3. Defendant Dawn Henry ... Commissioner of Defendant DPNR.
4. This is a civil action for breach of contract, breach of the implied covenant of good
faith and fair dealing, declaratory judgment, and equitable relief ... which this
Court has jurisdiction pursuant to 4 V.I.C. § 76.
EFTA00583185
GS!, LLC v. DPNR et al. Civil No. / 2017
Complaint Page 2
5. Venue is proper in this Court
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583185.pdf
EFTA00583127Set 9
2016-08-0414p3,731w
Islands.
2. Upon information and belief, Defendant the Department of Planning and Natural
Resources ("DPNR") is an instrumentality of the Government of the U.S. Virgin
Islands.
3. Defendant Dawn Henry ... Commissioner of Defendant DPNR.
4. This is a civil action for breach of contract, breach of the implied covenant of good
faith and fair dealing, declaratory judgment, and equitable relief ... which this
Court has jurisdiction pursuant to 4 V.I.C. § 76.
EFTA00583127
GS!, LLC v. DPNR et al. Civil No. / 2017
Complaint Page 2
5. Venue is proper in this Court
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583127.pdf
EFTA00583141Set 9
2016-08-0414p3,798w
Islands.
2. Upon information and belief, Defendant the Department of Planning and Natural
Resources ("DPNR") is an instrumentality of the Government of the U.S. Virgin
Islands.
3. Defendant Dawn Henry ... Commissioner of Defendant DPNR.
4. This is a civil action for breach of contract, breach of the implied covenant of good
faith and fair dealing, declaratory judgment, and equitable relief ... which this
Court has jurisdiction pursuant to 4 V.I.C. § 76.
EFTA00583141
GS!, LLC v. DPNR et al. Civil No. / 2017
Complaint Page 2
5. Venue is proper in this Court
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583141.pdf
EFTA01190090Set 9
2016-04-1810p1,975w
entered into by the VIRGIN ISLANDS
DEPARTMENT OF PLANNING AND NATURAL RESOURCES ("Complainant" or
"DPNR") and GREAT ST. JIM, LLC ("Respondent").
WITNESSETH:
WHEREAS, the Complainant is responsible for the administration ... Great St. James Island, St. Thomas, Virgin Islands (hereinafter "the Property").
EFTA01190090
Settlement Agreement
DPNR vs. Great St. Jim, LLC
NOVA-04- I 6-STT
Page 2 of 10
WHEREAS ... with soil allegedly intended for a building site (Please see NOVA
Exhibit Photos).
WHEREAS, DPNR acknowledges not all of the activities listed above were conducted by the
Respondent and various
https://www.justice.gov/epstein/files/DataSet%209/EFTA01190090.pdf
EFTA00582778Set 9
2016-11-174p2,468w
doing everything
it can to comply as quickly as possible with DPNR's directive in the Notice to Cure, albeit with little guidance
from DPNR as to how it should ... opportunity to review
and discuss them with your team.
• Paragraph 7H — Four Moorings. DPNR's citing the moorings as a violation of Section 3(a) of the
Settlement Agreement ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00582778.pdf
EFTA01733902Set 10
2016-04-189p1,916w
entered into by the VIRGIN ISLANDS
DEPARTMENT OF PLANNING AND NATURAL RESOURCES ("Complainant" or
"DPNR") and GREAT ST. JIM, LW ("Respondent").
WITNESSETH:
WHEREAS, the Complainant is responsible for the administration ... that revealed no permits or authorization letters for
EFTA_R1_00010599
EFTA01733902
Settlement Agreement
DPNR vs. Great St. Jim, LLC
NOVA-04-16417
Page 2 of 9
development or maintenance ... upon further investigation.
WHEREAS, Respondent has disputed Complainant's determinations as set forth by DPNR
in the NOVA.
EFTA_R1_00010600
EFTA01733903
Settlement Agreement
DPNR vs. Great
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01733902.pdf
EFTA00300105Set 9
2016-04-189p1,896w
entered into by the VIRGIN ISLANDS
DEPARTMENT OF PLANNING AND NATURAL RESOURCES ("Complainant' or
"DPNR") and GREAT ST. JIM, LLC ("Respondent").
WITNESSETH:
WHEREAS, the Complainant is responsible for the administration ... performed and that revealed no permits or authorization letters for
EFTA00300105
Settlement Agreement
DPNR vs. Great St. Jim, LLC
NOVA-04-16-STT
Page 2 of 9
development or maintenance ... upon further investigation.
WHEREAS, Respondent has disputed Complainant's determinations as set forth by DPNR
in the NOVA.
EFTA00300106
Settlement Agreement
DPNR vs. Great St. Jim, LLC
NOVA
https://www.justice.gov/epstein/files/DataSet%209/EFTA00300105.pdf
EFTA01735474Set 10
2016-11-178p2,203w
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
remaining items in Section ... extended to November 18, 2016. Now that our meeting is being rescheduled at DPNR's request for
Tuesday, November 22, 2016, a date after the November 18, 2016 deadline ... team and an extension of the cure deadline.
• Section I. Paragraph 711— Four Moorings. DPNR's citing the moorings as a violation of Section 3(a)
of the Settlement Agreement
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01735474.pdf
EFTA01222361Set 9
2010-12-1642p14,046w
TPDES Permit Administrator and
CEI Inspector are the authorized twicamtatives of the Commissioner of DPNR for the sole purpose of insuring the
following special conditions:
I. This permit ... along with EPA Form I
competed by the new owner. This is subject to DPNR
Commissioner's modification or revocation of the permit, pursua ... read and understood the permit
and all special conditions. In the case of foreclosure,
DPNR-DEP does not establish ownership.
4. In the event of leaks, spills or overflows
https://www.justice.gov/epstein/files/DataSet%209/EFTA01222361.pdf
EFTA01177160Set 9
2011-12-087p1,399w
RESOURCES
AND NAUTILUS, INC.
WHEREAS, the Complainant, the Department of Planning and Natural Resources
(DPNR), is responsible for the administration and enforcement of laws and regulations
pertaining to the protection ... Islands Code;
WHEREAS the Division of Coastal Zone Management (CZM) is a division of DPNR;
WHEREAS, Respondent, Nautilus, Inc. thereinafter "Respondent") is a duly registered
limited liability company conducting business ... operations at the northern point of Little
St. James, Cay.
EFTA01177160
Settlement Agreement
DPNR and NAUTILUS, INC.
Page 2
WHEREAS, the work conducted at Little St. James Cay listed herein
https://www.justice.gov/epstein/files/DataSet%209/EFTA01177160.pdf
EFTA00583721Set 9
2016-04-2510p1,829w
RESPONDENT. )
SUPPLEMENTAL CONSENT AGREEMENT
WHEREAS, the Complainant, the Department of Planning and Natural Resources
(DPNR), is responsible for the administration and enforcement of laws and regulations
pertaining to the protection ... about August 4, 2016, respondent entered into a Settlement
Agreement ("Settlement Agreement") with DPNR regarding issues pertaining to the NOVA; and
WHEREAS, on or about November 4, 2016, Complainant served ... interest bearing account and its terms, te-inekule
disbursements must be approved by DPNR. The account must be at a banking
institutien-loeateil-en-Str-Themas-US-V1,
CAfty-intefest
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583721.pdf
EFTA00300146Set 9
2011-12-086p1,380w
RESOURCES
AND NAUTILUS, INC.
WHEREAS, the Complainant, the Department of Planning and Natural Resources
(DPNR), is responsible for the administration and enforcement of laws and regulations
pertaining to the protection ... Islands Code;
WHEREAS the Division of Coastal Zone Management (CZM) is a division of DPNR;
WHEREAS, Respondent, Nautilus, Inc. thereinafter "Respondent") is a duly registered
corporation conducting its affairs ... been operated at the northern point
of Little St. James Cay.
EFTA00300146
Settlement Agreement
DPNR and NAUTILUS, INC.
Page 2
WHEREAS, DPNR/CZM concluded that the foregoing activities at Little
https://www.justice.gov/epstein/files/DataSet%209/EFTA00300146.pdf
EFTA00298097Set 9
2011-11-0120p7,411w
TPDES Permit Administrator and
CEI Inspector are the authorized representatives of the Commissioner of DPNR for the sole purpose of insuring the
following special conditions:
1. This permit ... along with EPA Form 1 competed by the new owner. This is subject to DPNR
Commissioner's modification or revocation of the permit, pursuant ... read and understood the permit and all special conditions. In the case of foreclosure,
DPNR-DEP does not establish ownership.
4. In the event of leaks, spills or overflows
https://www.justice.gov/epstein/files/DataSet%209/EFTA00298097.pdf
EFTA00591225Set 9
2011-12-086p1,382w
RESOURCES
AND NAUTILUS, INC.
WHEREAS, the Complainant, the Department of Planning and Natural Resources
(DPNR), is responsible for the administration and enforcement of laws and regulations
pertaining to the protection ... Islands Code;
WHEREAS the Division of Coastal Zone Management (CZM) is a division of DPNR;
WHEREAS, Respondent, Nautilus, Inc. (hereinafter "Respondent") is a duly registered
corporation conducting its affairs ... been operated at the northern point
of Little St. James Cay.
EFTA00591225
Settlement Agreement
DPNR and NAUTILUS, INC.
Page 2
WHEREAS, DPNR/CZM concluded that the foregoing activities at Little
https://www.justice.gov/epstein/files/DataSet%209/EFTA00591225.pdf
EFTA01121120Set 9
2011-12-086p1,382w
RESOURCES
AND NAUTILUS, INC.
WHEREAS, the Complainant, the Department of Planning and Natural Resources
(DPNR), is responsible for the administration and enforcement of laws and regulations
pertaining to the protection ... Islands Code;
WHEREAS the Division of Coastal Zone Management (CZM) is a division of DPNR;
WHEREAS, Respondent, Nautilus, Inc. (hereinafter "Respondent") is a duly registered
corporation conducting its affairs ... been operated at the northern point
of Little St. James Cay.
EFTA01121120
Settlement Agreement
DPNR and NAUTILUS, INC.
Page 2
WHEREAS, DPNR/CZM concluded that the foregoing activities at Little
https://www.justice.gov/epstein/files/DataSet%209/EFTA01121120.pdf
EFTA01121126Set 9
2011-12-086p1,382w
RESOURCES
AND NAUTILUS, INC.
WHEREAS, the Complainant, the Department of Planning and Natural Resources
(DPNR), is responsible for the administration and enforcement of laws and regulations
pertaining to the protection ... Islands Code;
WHEREAS the Division of Coastal Zone Management (CZM) is a division of DPNR;
WHEREAS, Respondent, Nautilus, Inc. (hereinafter "Respondent") is a duly registered
corporation conducting its affairs ... been operated at the northern point
of Little St. James Cay.
EFTA01121126
Settlement Agreement
DPNR and NAUTILUS, INC.
Page 2
WHEREAS, DPNR/CZM concluded that the foregoing activities at Little
https://www.justice.gov/epstein/files/DataSet%209/EFTA01121126.pdf
EFTA00586978Set 9
2016-04-258p1,707w
RESPONDENT. )
SUPPLEMENTAL CONSENT AGREEMENT
WHEREAS, the Complainant, the Department of Planning and Natural Resources
(DPNR), is responsible for the administration and enforcement of laws and regulations
pertaining to the protection ... about August 4, 2016, respondent entered into a Settlement
Agreement ("Settlement Agreement") with DPNR regarding issues pertaining to the NOVA; and
WHEREAS, on or about November 4, 2016, Complainant served ... said laws, regulations, or permits raised by any territorial or
federal agency other than DPNR.
3. Release
DPNR fully and unconditionally releases and discharges Respondent and its successors,
assigns, members
https://www.justice.gov/epstein/files/DataSet%209/EFTA00586978.pdf