EFTA00583155.pdf

IN THE 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 ) In Her Official Capacity as Commissioner of the ) Department of Planning and Natural Resources, ) ) Defendants. ) ) PLAINTIFF'S RULE 26 INITIAL DISCLOSURES COMES NOW Plaintiff GREAT St. JIM, LLC, by and through KELLERHALS FERGUSON ICROBLIN PLLC, and hereby submits the following for its Rule 26 Initial Disclosures. Plaintiff reserves the right to supplement this response. I. The name and, if known, the address and telephone number of each individual likely to have discoverable information that Plaintiff may use to support its claims or defenses. a. Plaintiff - can be contacted through counsel. b. Dawn Henry c. 2. A copy, or description by category and location, of all documents, electronically stored information, and tangible things that Plaintiff has in its possession, custody, or control and may use to support its claims and defenses. 3. A computation of each category of damages claimed by Plaintiff. a. Cost to move moorings: b. Loss of use EFTA00583155 Great St. Jim, LLC v. DPNR Civil No. / 2017 Plaintiff's Rule 26 Initial Disclosures Page 2 $20,000 per day x days = c. d. Any and all costs of prosecuting this action, including legal fees, which Plaintiff has incurred and continues to incur in association with this suit. e. Plaintiff is still investigating its losses and reserves the right to amend the foregoing. 4. Any insurance agreement under which an insurance business may be liable to satisfy all, or part, of a possible judgment in the action or to indemnify or reimburse for payments made to satisfy the judgment. Not applicable. Respectfully, Dated: December 2016 CHRISTOPHER ALLEN KROBLIN, ESQ. MARJORIE WHALEN, ESQ. KELLERHALS FERGUSON KROBLIN PLLC V.I. Bar Nos. 966 and R2019 Royal Palms Professional Building 9053 Estate Thomas, Suite 101 St. Thomas, V.I. 00802 Telephone: (340) 779-2564 Facsimile: (888)316-9269 Email: EFTA00583156 Great St. Jim, LLC v. DPNR Civil No. / 2017 Plaintiff's Rule 26 Initial Disclosures Page 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this day of December, 2016, I caused a true and exact copy of the foregoing Plaintiff's Rule 26 Disclosures to be served via first class mail, postage prepaid, upon: EFTA00583157