Kellerhals Ferguson Kroblin PLLC Royal Palms Professional Building, 9053 Estate Thomas, Suite 101, St. Thomas, V.l. 00802 340.779.2564 Telephone I 1.888.316.9269 Fax I www.kellfer.com November 17, 2016 Via Hand Delivery & Electronic Mail Michele Baker, Esq. Legal Counsel Division of Coastal Zone Management 8100 Lindberg Bay, Suite 61 Cyril E. King Airport Terminal Building 2nd Floor St. Thomas, VI 00802 [email protected] Re: Notice to Cure & NOVA-04-16-STT 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 removed both the concrete pad and the foundation materials referred to in 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's directive in the Notice to Cure, albeit with little guidance from DPNR as to how it should do so. However, in continuing work with regard to the remaining items in Section I, Paragraph 7 of the Notice to Cure, there are a number of significant issues which require clarification. Those issues would have been addressed at the meeting scheduled for November 16, 2016 in advance of the cure deadline, which pursuant to your email, dated November 14, 2016, was extended to November 18, 2016. Now that our meeting is being rescheduled to a date after the November 18, 2016 deadline, in order to avoid any misunderstandings, violations and unintended environmental consequences, I would respectfully request written clarification of the matters below after you have an 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 and 12 VIC §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