EFTA01074706Set 9
2015-09-0288p20,428w
September 3, 2015, motion to dismiss the Information
as time-barred pursuant to V.I. Code Ann. tit. 5, § 3541(a)(2), Gov. de Jongh is charged with one
count each ... violating V.I. Code Ann. tit. 14, § 1662(1) and V.I. Code Ann. tit. 14, § 1663(1).
The allegations are based on events that took place in 2007-2008, that transpired ... bidding. On
August 18, 2015, Gov. de Jongh was arrested for purportedly violating V.I. Code Ann. tit. 14, §
1662(1) and V.I. Code Ann. tit. 14, § 1663(1).
ARGUMENT
https://www.justice.gov/epstein/files/DataSet%209/EFTA01074706.pdf
EFTA00603188Set 9
2012-03-089p3,032w
CORRECTIVE ACTION
) AND NOTICE OF
) OPPORTUNITY FOR
) HEARING
VS. )
)
NAUTILUS, INC. )
)
)
RESPONDENT. )
)
PROCEEDING UNDER V.I. CODE ANN. TIT. 12. SECTION 913(6)
OF THE COASTAL ZONE MANAGEMENT ACT.
L AUTHORITY ... Consistent with the policy of the United States Virgin Islands, as declared in V.I. Code Ann.
tit. 12, Section 903(bX1), to protect, maintain, preserve and where feasible, enhance ... NOTICE OF OPPORTUNITY FOR. HEARING, in accordance
with the authority conferred upon him by V.I. Code Ann. tit. 12, Section 913(bX6).
Received Time Mar. 8. 2012 1:01PM
https://www.justice.gov/epstein/files/DataSet%209/EFTA00603188.pdf
EFTA01113608Set 9
2012-03-089p3,035w
CORRECTIVE ACTION
) AND NOTICE OF
) OPPORTUNITY FOR
) HEARING
VS. )
)
NAUTILUS, INC. )
)
)
RESPONDENT. )
)
PROCEEDING UNDER V.I. CODE ANN. TIT. 12. SECTION 913(6)
OF THE COASTAL ZONE MANAGEMENT ACT.
L AUTHORITY ... Consistent with the policy of the United States Virgin Islands, as declared in V.I. Code Ann.
tit. 12, Section 903(bX1), to protect, maintain, preserve and where feasible, enhance ... NOTICE OF OPPORTUNITY FOR. HEARING, in accordance
with the authority conferred upon him by V.I. Code Ann. tit. 12, Section 913(bX6).
Received Time Mar. 8. 2012 1:01PM
https://www.justice.gov/epstein/files/DataSet%209/EFTA01113608.pdf
EFTA01077958Set 9
2013-08-2111p2,812w
construed to limit the Commission's rights, duties and responsibilities
under Title 29 V.I. Code Section 722 or Subchapter 722 of the Regulations.
8. Beneficiary shall commence the active conduct ... that if
the Beneficiary complies with the conditions herein, the provisions of Title 29 V.I. Code,
Chapter 12 as existing on the date of the Governor's approval, the Rules ... Regulations
of the Commission promulgated in accordance with Title 29 V.I. Code Section 705(f) and
all applicable laws and regulations of the Territory of the Virgin Islands
https://www.justice.gov/epstein/files/DataSet%209/EFTA01077958.pdf
EFTA01222361Set 9
2010-12-1642p14,046w
This Territorial Pollutant Discharge Elimination System (TPDES) permit is issued in compliance with 12 V.I. CODE
ANN. § 185 in accordance with the provisions of the Federal Water Pollution Control ... that time, in accordance with 12 V.I. R. & REGS. § 184-26,
pursuant to 12 V.I. CODE ANN. § 184 (a) and (p) and (q) (1976).
Annually, the manager, operator or contact ... violations of permit conditions including any interim schedule of compliance,
pursuant to 12 V.I.
CODE ANN. § 185 (f) 2 (A) and (i) (2000). The Permit Administrator, CEI inspector
https://www.justice.gov/epstein/files/DataSet%209/EFTA01222361.pdf
EFTA01222235Set 9
2011-02-0784p23,167w
This Territorial Pollutant Discharge Elimination System (TPDES) permit is issued in compliance with 12 V.I. CODE
ANN. § 185 in accordance with the provisions of the Federal Water Pollution Control ... that time, in accordance with 12 V.I. R. & REGS. § 184-26,
pursuant to 12 V.I. CODE ANN. § 184 (a) and (p) and (q) (1976).
Annually, the manager, operator or contact ... violations of permit conditions including any interim schedule of compliance,
pursuant to 12 V.I.
CODE ANN. § 185 (f) 2 (A) and (i) (2000). The Permit Administrator, CEI inspector
https://www.justice.gov/epstein/files/DataSet%209/EFTA01222235.pdf
EFTA01407189Set 10
2016-10-12100p20,728w
husband acquired the property from his mother, the
husband was
awarded possession under V.I. Code Ann. tit. 33, § 2305(d), minus an award
to the wife for
her interest ... contributions; [2]-The wife's medical degree was not
marital property
under V.I. Code Ann. tit. 16, § 109, as the husband had not been compelled
to delay or
relinquish ... joint personal
property and real property, limited to the marital homestead as defined in
V.I. Code Ann.
tit. 33, § 2305(d). Real property owned by the couple, other than
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01407189.pdf
EFTA01295845Set 10
2016-10-1252p21,251w
husband acquired the property from his mother. the husband was
awarded possession under V.I. Code Ann. tit. 33. § 2305(d). minus an award to the wife for
her interest ... contributions; [2]-The wife's medical degree was not marital property
under V.I. Code Ann. tit. 16. § 109, as the husband had not been compelled to delay or
relinquish ... joint personal
property and real property, limited to the marital homestead as defined in V.I. Code Ann.
tit. 33, § 2305(d). Real property owned by the couple, other than
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01295845.pdf
EFTA01297082Set 10
2017-07-1143p15,935w
husband acquired the property...Lam his mother, the husband was
awarded possession under V.I. Code Ann. tit. 33. §IM(d). minus an award to the wife for
her interest ... contributions: [2]-The wife's medical degree was not marital property
under V.I. Code Ann. tit. 16. § 109, as the husband had not been compelled to delay or
relinquish ... divide joint personal
property •eal property, limited to the marital homestead as defined in V.I. Code Ann.
tit. 33, § (d). Real property owned by the couple, other than the marital
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01297082.pdf
EFTA01086686Set 9
2000-09-1443p11,378w
requested pursuant to V.I. Code, Title 12,
Section 910 (e) and V.I. R®S, Title 12, Section 910-15 (b).
2). SCOPE. The scope of work described in CZM Major ... Natural Resources (DPNR) on behalf of the Coast
al Zone
Management Commission pursuant to V.I. Code, tit 12, section 910 and 911, and any
other
provisions of the Coastal Zone ... project engineer
that the plans and specifications of the projec
t and all applicable V.I. Code
requirements have been met, shall be filed with said
Director.
2
COW?) lnawaSemm dao7
https://www.justice.gov/epstein/files/DataSet%209/EFTA01086686.pdf
EFTA00791800Set 9
2011-10-1817p5,063w
Forged
Instrument in the Superior Court of the Virgin Islands in violation of V.I. Code Ann. tit.14,
Section 7951; (Case Number ST-09-CR-332). He was sentenced ... Court of the Virgin Islands for Assault in the Third Degree, in violation of
V.I. Code Ann. tit. 14, Section 297(4). He was sentenced to a term of imprisonment ... convicted of Making Fraudulent Claims on the Virgin Islands Government in violation of V.I.
Code Ann tit 14, section 843 in the Superior Court of the Virgin Islands (Case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00791800.pdf
EFTA00298097Set 9
2011-11-0120p7,411w
This Territorial Pollutant Discharge Elimination System (TPDES) permit is issued in compliance with 12 V.I. CODE
ANN. § 185 in accordance with the provisions of the Federal Water Pollution Control ... that time, in accordance with 12 V.I. It & REGS. § 184-26,
pursuant to 12 V.i. CODE ANN. § 184 (a) and (p) and (q) (1976).
Annually, the manager, operator or contact ... violations of permit conditions including any interim schedule of compliance, pursuant to 12 V.i.
CODE ANN. § 185 (0 2 (A) and (i) (2000). The Permit Administrator, CEi inspector
https://www.justice.gov/epstein/files/DataSet%209/EFTA00298097.pdf
EFTA00727606Set 9
2009-06-2216p3,888w
award of prejudgment interest is
permitted on "all monies which have become due." V.I. Code Ann.
tit. 11, § 951(a)(1). "Award is authorized . . . only where the
amount ... breach of contract award against the Sellers shall
accrue at the rate prescribed by V.I. CODE ANN. tit. 11, § 951,
from September 22, 2004 until the date of this Judgment ... claims on which judgment has been entered shall accrue at the
rate prescribed by V.I. CODE ANN. tit. 5, § 426, from the date of
this Judgment until the date
https://www.justice.gov/epstein/files/DataSet%209/EFTA00727606.pdf
EFTA00307083Set 9
2011-05-2413p5,972w
McClellan v. Rd ofCry. Comm In, 261 P.R.D. 595, 603 (N.D. 0kla. 2009).
V.I. CODE ANN. tit. 5, § 4911 (1997).
° SUPER. Cr. R. 27(b) ("The summons and process shall ... Puerto Rico Corp, 314 F. Supp.
it 2d 495, 499 (D. V.1. 2004).
V.I. CODE ANN. tit. 5, *4903 (1997).
Moron. IVextran ... RESTATEMENT (SECOND) OF CONTRACTS § 302(1) (1981); V.I. CODE ANN. tit. I, § 4 (1994) (in the absence of
oval law to the contrary, the Restatements provide the rules of decision
https://www.justice.gov/epstein/files/DataSet%209/EFTA00307083.pdf
EFTA00730479Set 9
2010-11-0111p5,330w
parties as the economic development program or EDP), currently codified at V.I. Code Ann.
tit. 29, secs. 701-726 (1998 & Supp. 2010). Intended to promote growth and the development ... certain industrial
development benefits to companies that do business in the Virgin Islands. See V.I. Code Ann.
tit. 29, sec. 701 (1998). Qualifying companies receive substantial benefits including
https://www.justice.gov/epstein/files/DataSet%209/EFTA00730479.pdf
EFTA01104787Set 9
2014-12-1911p2,687w
Division of Banking and Insurance,
Office of the Lieutenant Govemor("Division") by V.I. CODE ANN. tit 9, Subchapter II, §736-
754 and in the name of the Government ... Director finds that the Beneficiary
is an eligible new Beneficiary pursuant to V.I. Code Ann. Chapter 25, Title 9. The grant of
benefits hereinafter described is for the Beneficiary
https://www.justice.gov/epstein/files/DataSet%209/EFTA01104787.pdf