EFTA00583721Set 9
2016-04-2510p1,829w
CURE
COMPLAINANT, ) BREACH OF SETTLEMENT
) AGREEMENT AND
vs. ) ENFORCEMENT OF SETTLEMENT
) AGREEMENT
GREAT ST. JIM, LLC )
)
)
)
RESPONDENT. )
SUPPLEMENTAL CONSENT AGREEMENT
WHEREAS, the Complainant, the Department of Planning and Natural Resources ... Violation No. NOVA-04-16-STT dated
April 22, 2016 ("NOVA"); and
EFTA00583721
Great St. Jim
NOVA-04-I6-STT
Supplemental Consent Agreement
Page 2 of 10
WHEREAS ... grant to the St. Thomas Historical Trust, an exempt entity under Section
EFTA00583722
Great St. Jim
NOVA-04-I6-STT
Supplemental Consent Agreement
Page
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583721.pdf
EFTA00161836Set 9
2023-01-10122p31,654w
TRUST;
ESTATE OF JEFFREY E. EPSTEIN; THE 1953
TRUST; PLAN D, LLC; GREAT ST. JIM, LLC;
NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR,
Inc.; SOUTHERN TRUST COMPANY, INC.;
CYPRESS, INC.; MAPLE ... 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 ... Virgin Islands. Great St. Jim, LLC was organized on October 26,
2015. Great St. Jim, LLC, according to records of the Virgin Islands Recorder of Deeds, owns at
least three
https://www.justice.gov/epstein/files/DataSet%209/EFTA00161836.pdf
EFTA00805272Set 9
2017-07-3156p12,681w
SUPERIOR COURT OF THE VIRGIN ISLAND
DIVISION OF ST. THOMAS & ST. JOHN
GREAT St JIM, LLC
Civil No. ST-I8-CV-29
Plaintiff,
v. ACTION FOR ENFORCEMENT
OF COVENANT, INJUNCTIVE ... failure to state a claim for which relief can be granted.
Plaintiff Great St. Jim ("GS Jim") in the FAC seeks to enforce an alleged historical
restrictive covenant that burdens ... Rules of Civil Procedure mandates that "[a] pleading that states a claim
EFTA00805272
Great St. Jim, LLC, v. Kjacr, el at.
Motion to Dismiss the First Amended Complaint
Page
https://www.justice.gov/epstein/files/DataSet%209/EFTA00805272.pdf
EFTA00583891Set 9
2016-04-2511p2,021w
CURE
COMPLAINANT, ) BREACH OF SETTLEMENT
) AGREEMENT AND
vs. ) ENFORCEMENT OF SETTLEMENT
) AGREEMENT
GREAT ST. JIM, LLC )
)
)
)
RESPONDENT. )
SUPPLEMENTAL CONSENT AGREEMENT
WHEREAS, the Complainant, the Department of Planning and Natural Resources ... Complainant and Respondent are hereinafter
referred to collectively as the "Parties"); and
EFTA00583891
Great St. Jim
NOVA-04- 16-ST1'
Supplemental Consent Agreement
Page 2 of 11
WHEREAS ... ceinplainant—and—Respendent—afe—eelleetively—Fefecced—te—herein—as—the
Paftiestand
2
EFTA00583892
Great St. Jim
NOVA-04-16-STT
Supplemental Consent Agreement
Page 3 of 11
WHEREAS, Respondent neither
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583891.pdf
EFTA01227326Set 9
2016-01-21100p24,232w
UNCLASSIFIED
Title: (U) Two Deeds for Great St James Island purchased by GREAT ST JIM
LLC in January 2016.
Re: 31E-NY-3027571-FF, 08/21/2019
JIM LLC in January ... Deeds, additional parcels.
Details:
Two Deeds for Great St James Island purchased by GREAT ST JIM LLC in
January 2016, obtained from U.S. Virgin Islands Recorder of Deeds
database ... January 18,2016, Parcels A, A-1 and A-2, were conveyed to GREAT ST
JIM LLC for consideration in the amount of $17,500,00.00.
On January
https://www.justice.gov/epstein/files/DataSet%209/EFTA01227326.pdf
EFTA00803005Set 9
66p16,444w
BARGE
LANDING
ON GREAT ST. JAMES ISLAND
U.S. VIRGIN ISLANDS
PREPARED FOR
GREAT ST. JIM, LLC.
PREPARED BY
BIOIMPACT, INC.
P.O. BOX 132
KINGSHILL, ST. CROIX
U.S. VIRGIN ISLANDS ... Tree Boa Protection Plan
ii
EFTA00803007
1.0 NAME AND ADDRESS OF APPLICANT
Great St. Jim, LLC
9053 Estate St. Thomas, Suite 101
St. Thomas, VI 00802
2.0 LOCATION OF PROJECT ... showing Great St. James Island in relationship to the
surrounding area.
3.00 ABSTRACT
Great St. Jim, LLC is seeking to construct two docks, one of which is a combination
dock
https://www.justice.gov/epstein/files/DataSet%209/EFTA00803005.pdf
EFTA00807018Set 9
2017-03-3120p6,780w
SUPERIOR COURT OF THE VIRGIN ISLANDS
DIVISION OF ST. THOMAS & ST. JOHN
**********************************
GREAT ST. JIM, LLC, )
) CIVIL NO. ST-18-CV-293
Plaintiff, )
) ACTION FOR ENFORCEMENT
v. ) OF COVENANT, INJUNCTIVE ... ACCOUNTING
)
Defendant. )
)
OPPOSITION TO MOTION TO DISMISS FIRST AMENDED COMPLAINT
COMES NOW, Plaintiff GREAT ST. JIM, LLC, by and through its undersigned counsel
KELLERHALS FERGUSON KRoBLEN PLLC, and hereby opposes ... thereof states as
follows:
I. Defendants' Motion to Dismiss Must be Denied
Plaintiff Great St. Jim, LLC ("GSJ") filed its First Amended Complaint to enforce its
property rights in Parcel
https://www.justice.gov/epstein/files/DataSet%209/EFTA00807018.pdf
EFTA00300105Set 9
2016-04-189p1,896w
GOVERNMENT OF THE VIRGIN ISLANDS
DEPARTMENT OF PLANNING AND NATURAL RESOURCES
AND
GREAT ST. JIM, LLC
THIS SETTLEMENT AGREEMENT is entered into by the VIRGIN ISLANDS
DEPARTMENT OF PLANNING ... NATURAL RESOURCES ("Complainant' or
"DPNR") and GREAT ST. JIM, LLC ("Respondent").
WITNESSETH:
WHEREAS, the Complainant is responsible for the administration and enforcement of
laws and regulations pertaining to the protection ... Division of Coastal Zone Management
("CZM") is a division thereof;
WHEREAS, the Respondent, Great St. Jim, LLC, a Virgin Islands limited liability company,
(hereinafter "the Respondent"), is a person
https://www.justice.gov/epstein/files/DataSet%209/EFTA00300105.pdf
EFTA00104291Set 9
2020-01-1549p13,383w
JEFFREY E. EPSTEIN, THE 1953 JURY TRIAL DEMANDRD
TRUST, PLAN D, LLC; GREAT ST. JIM, LLC;
NAUTILUS, INC.; HYPERION AIR, LLC;
POPLAR, INC., JOHN AND JANE DOES
rs
DEFENDANTS,
COMPLAINT ... 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 ... Virgin Islands. Great St. Jim, LLC was organized on October 26,
2015. Great St. Jim, LLC, according to records of the Virgin Islands Recorder of Deeds, owns at
least three
https://www.justice.gov/epstein/files/DataSet%209/EFTA00104291.pdf
EFTA00802602Set 9
121p30,403w
BARGE LANDING
ON GREAT ST. JAMES ISLAND
U.S. VIRGIN ISLANDS
PREPARED FOR
GREAT ST. JIM, LLC.
PREPARED BY
BIOIMPACT, INC.
M. BOX 132
KINGSHILL, ST. CROIX
U.S. VIRGIN ISLANDS ... Access Dock, and a Combination Dock and Barge Landing
Dear Commissioner Henry,
Great St. Jim, LLC wishes to make application to the Virgin Islands Government and the Secretary ... Owner of property and Agent (if any)
Owner of Property(s) AMR
Great St Jim, LLC Erika A. Kellerhals
9053 Estate SL Thomas. Suite 101 IIIII••••••••••0410la
https://www.justice.gov/epstein/files/DataSet%209/EFTA00802602.pdf
EFTA00808406Set 9
2016-04-2510p1,730w
CURE
COMPLAINANT, ) BREACH OF SETTLEMENT
) AGREEMENT AND
vs. ) ENFORCEMENT OF SETTLEMENT
) AGREEMENT
GREAT ST. JIM, LLC )
)
)
)
RESPONDENT. )
SUPPLEMENTAL CONSENT AGREEMENT
WHEREAS, the Complainant, the Department of Planning and Natural Resources ... Violation No. NOVA-04-16-STT dated
April 22, 2016 ("NOVA"); and
EFTA00808406
Great St. Jim
NOVA-04-I6-STT
Supplemental Consent Agreement
Page 2 of 10
WHEREAS ... grant to the St. Thomas Historical Trust, an exempt entity under Section
EFTA00808407
Great St. Jim
NOVA-04-I6-STT
Supplemental Consent Agreement
Page
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808406.pdf
EFTA01733902Set 10
2016-04-189p1,916w
GOVERNMENT OF THE VIRGIN ISLANDS
DEPARTMENT OF PLANNING AND NATURAL RESOURCES
AND
GREAT ST. JIM, LLC
THIS SETTLEMENT AGREEMENT is entered into by the VIRGIN ISLANDS
DEPARTMENT OF PLANNING ... NATURAL RESOURCES ("Complainant" or
"DPNR") and GREAT ST. JIM, LW ("Respondent").
WITNESSETH:
WHEREAS, the Complainant is responsible for the administration and enforcement of
laws and regulations pertaining to the protection ... Division of Coastal Zone Management
("CZM") is a division thereof;
WHEREAS, the Respondent, Great St. Jim, LLC, a Virgin Islands limited liability company.
(hereinafter "the Respondent"), is a person
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01733902.pdf
EFTA00583185Set 9
2016-08-0416p4,364w
SUPERIOR COURT OF THE VIRGIN ISLANDS
DISTRICT OF ST. THOMAS & ST. JOHN
**********************************
GREAT ST. JIM, LLC, )
) CIVIL NO. 12017
Plaintiff, )
)
v. )
)
DEPARTMENT OF PLANNING AND )
NATURAL RESOURCES and DAWN HENRY ... Department of Planning and Natural Resources, )
)
Defendants. )
)
COMPLAINT
COMES NOW Plaintiff Great St. Jim, LLC, by and through its undersigned counsel,
ICELLERHALS FERGUSON KROBLIN PLLC, and for its Complaint against ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583185.pdf
EFTA00583158Set 9
2016-08-0422p6,313w
SUPERIOR COURT OF THE VIRGIN ISLANDS
DISTRICT OF ST. THOMAS & ST. JOHN
**********************************
GREAT ST. JIM, LLC, )
) CIVIL NO. 12017
Plaintiff, )
)
v. )
)
DEPARTMENT OF PLANNING AND )
NATURAL RESOURCES and DAWN HENRY ... Department of Planning and Natural Resources, )
)
Defendants. )
)
COMPLAINT
COMES NOW Plaintiff Great St. Jim, LLC, by and through its undersigned counsel,
ICELLERHALs FERGUSON KROBLIN PLLC, and for its Complaint against ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583158.pdf
EFTA01735474Set 10
2016-11-178p2,203w
Dear Attorney Baker:
I wanted to let you know that Great St. Jim, LLC is well underway in addressing the items set forth in the
Notice to Cure, having completely ... 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 ... Settlement Agreement, however these moorings were in place prior to Great St Jim, 1..LC's
acquisition of Great St. James Island. See attached Google Earth image from
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01735474.pdf
EFTA00582778Set 9
2016-11-174p2,468w
Dear Attorney Baker:
I wanted to let you know that Great St. Jim, LLC is well underway in addressing the items set forth in the
Notice to Cure, having completely ... Section I, Paragraphs 7A and 7C, respectively, of the Notice to Cure. Great St. Jim, LLC is doing everything
it can to comply as quickly as possible with DPNR ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00582778.pdf
EFTA00104216Set 9
2019-08-1049p12,907w
JEFFREY E. EPSTEIN, THE 1953 JURY TRIAL DEMANDED
TRUST, PLAN D, LLC; GREAT ST. JIM, LLC;
NAUTILUS, INC.; HYPERION AIR, LLC;
POPLAR, INC., JOHN AND JANE DOES
DEFENDANTS,
COMPLAINT
COMES ... 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 ... Virgin Islands. Great St. Jim, LLC was organized on October 26,
2015. Great St. Jim, LLC, according to records of the Virgin Islands Recorder of Deeds, owns at
least three
https://www.justice.gov/epstein/files/DataSet%209/EFTA00104216.pdf
EFTA00802723Set 9
114p30,682w
BARGE
LANDING
ON GREAT ST. JAMES ISLAND
U.S. VIRGIN ISLANDS
PREPARED FOR
GREAT ST. JIM, LLC.
PREPARED BY
BIOIMPACT, INC.
BOX 132
KINGSHILL, ST. CROIX
U.S. VIRGIN ISLANDS 00851
bioimpact@islands.vi ... Pearson Artificial Reef Information
ii
EFTA00802725
1.0 NAME AND ADDRESS OF APPLICANT
Great St. Jim, LLC
9053 Estate St. Thomas, Suite 101
St. Thomas, VI 00802
2.0 LOCATION OF PROJECT ... showing Great St. James Island in relationship to the
surrounding area.
3.00 ABSTRACT
Great St. Jim, LLC is seeking to construct two docks, one of which is a combination
dock
https://www.justice.gov/epstein/files/DataSet%209/EFTA00802723.pdf
EFTA01307833Set 10
2016-01-215p1,236w
Passage. Suites 18B and 1W St. Thomas. USVI 00802. (hereinafter the
"Grantor") and Great St. Jim. LLC. a Virgin Islands Limited Liability Company. c/o Kellerhals Ferguson
Krohlin PLLC. Royal Palms ... above mentioned
propimiyhoAdAch,accork,gig
to WARRANTY DEED dated January 21, 2016
GREAT ST. JIM, LLC, a Virgin Islands Limited Liability Company (GRANTEE)
bei0nfilg tO*
has not according
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01307833.pdf
EFTA00583127Set 9
2016-08-0414p3,731w
SUPERIOR COURT OF THE VIRGIN ISLANDS
DISTRICT OF ST. THOMAS & ST. JOHN
**********************************
GREAT ST. JIM, LLC, )
) CIVIL NO. 12017
Plaintiff, )
)
v. )
)
DEPARTMENT OF PLANNING AND )
NATURAL RESOURCES and DAWN HENRY ... Department of Planning and Natural Resources, )
)
Defendants. )
)
COMPLAINT
COMES NOW Plaintiff Great St. Jim, LLC, by and through its undersigned counsel,
ICELLERHALS FERGUSON KROBLIN PLLC, and for its Complaint against ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583127.pdf