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Zoning & Property Use Cases

Snapshot

Zoning and property use records connected to Jeffrey Epstein include building permits, coastal development approvals, environmental enforcement actions, state land leases, inspection disputes, property holding companies, demolition approvals, and civil cases involving properties allegedly used in Epstein’s trafficking operation.

The strongest documented land use enforcement occurred in the United States Virgin Islands. The Virgin Islands Department of Planning and Natural Resources brought an administrative proceeding against Great St. Jim, LLC over unauthorized development on Great St. James. The dispute produced a notice of violation, a settlement agreement, notices alleging failure to cure, and a supplemental consent agreement.

New Mexico separately canceled two state grazing leases associated with Zorro Ranch in 2019. Cypress, Inc., the Epstein controlled company holding the ranch, initially contested the cancellation but later abandoned the challenge.

Other Epstein properties were central to criminal investigations and survivor lawsuits, but their use as locations of alleged abuse does not automatically make those proceedings zoning cases. No reliable primary record has been identified establishing the broad series of zoning violations previously attributed to Epstein’s Manhattan townhouse or Palm Beach mansion.

The relevant records must therefore be separated into four categories:

  1. Zoning and coastal development enforcement
  2. Government land lease proceedings
  3. Civil claims involving the use or ownership of a property
  4. Postmortem sale, demolition, remediation, and redevelopment proceedings

These categories overlap, but they are not legally interchangeable.


What “Zoning and Property Use Cases” Means

“Zoning and Property Use Cases” is an EpsteinWiki research classification. It is not the title of one lawsuit or a formal body of Epstein specific law.

The classification includes:

  1. Administrative enforcement by planning and environmental agencies
  2. Disputes over building and coastal development permits
  3. Government inspections of construction work
  4. Public land lease cancellations
  5. Environmental remediation obligations
  6. Civil cases naming property holding companies
  7. Forfeiture, sale, and liquidation of properties connected to alleged criminal activity
  8. Demolition and redevelopment approvals after Epstein’s death

A notice of violation is not a criminal conviction. A permit application does not establish that the proposed work was completed. A civil complaint records a plaintiff’s allegations. A consent agreement may resolve disputed conduct without an admission of liability.

Those distinctions are particularly important in the Epstein record, where property documents are frequently used to make claims far beyond what the documents actually prove.


Epstein’s Property Holding Structure

Epstein commonly held real estate through corporations, limited liability companies, trusts, and other entities rather than in his own name.

The principal entities included:

  1. Nautilus, Inc., which held Little St. James
  2. Great St. Jim, LLC, which held Great St. James
  3. Poplar, Inc., which held the membership interests in Great St. Jim, LLC
  4. Cypress, Inc., which held Zorro Ranch and associated interests in New Mexico
  5. Laurel, Inc., which held the Palm Beach property at 358 El Brillo Way
  6. Maple, Inc., which held the Manhattan townhouse at 9 East 71st Street
  7. SCI JEP, which held Epstein’s interests in units at 22 Avenue Foch in Paris

The released EFTA01266204, containing a confidential trust document, identifies these properties, their holding entities, and associated permits, improvements, fixtures, and rights.

Corporate ownership is relevant because zoning notices, permits, leases, deeds, and lawsuits may name the holding company rather than Epstein personally. It does not follow that every officer, employee, lawyer, or registered agent of a property company participated in illegal activity.


Coastal Regulation in the U.S. Virgin Islands

Development on Little St. James and Great St. James was regulated by the Virgin Islands Department of Planning and Natural Resources, commonly called DPNR.

Within DPNR, the Division of Coastal Zone Management administers the Virgin Islands Coastal Zone Management Act. Depending on the location and scale of a project, construction may require coastal permits, environmental assessments, water quality approvals, earth change permits, building permits, or authorization from federal agencies such as the United States Army Corps of Engineers.

The legal questions can include:

  1. Whether work occurred within the coastal zone
  2. Whether a project required a major or minor coastal permit
  3. Whether land was cleared before approval
  4. Whether roads, docks, ramps, jetties, utilities, or buildings matched approved plans
  5. Whether construction affected submerged lands, coral, erosion, or protected species
  6. Whether inspectors were allowed to examine the work
  7. Whether a permit issued by one agency satisfied requirements imposed by another

Approval from the Army Corps of Engineers, for example, would not necessarily eliminate the need for a territorial coastal permit.


Little St. James Permit Records

Epstein acquired Little St. James through L.S.J., LLC in 1998. Title was later transferred to Nautilus, Inc.

EFTA01305148 contains the recorded property transfer and Epstein’s affidavit identifying himself as president and sole beneficial owner of Nautilus and sole member of the transferring company.

The released evidence inventory in EFTA00299879 identifies extensive Little St. James permitting files. The inventory references:

  1. Coastal Zone Management permits
  2. A permit for the main two story residence
  3. Utility building permits
  4. Dock permits and modifications
  5. Applications involving a rock groin
  6. Water permit issues
  7. Environmental assessment reports
  8. Beach sand and dredging records
  9. A floating dock modification
  10. A pool, cabana, guest house, woodshop, library, and office pavilion
  11. Applications involving shoreline work and stabilization
  12. Minor permits issued in 2010

This inventory proves that investigators obtained files bearing those descriptions. It does not by itself prove that every listed project was built, that every project violated a permit, or that the contents of each folder were complete.

The record does establish that Little St. James was a heavily developed private island subject to repeated interactions with territorial and federal regulators.


Great St. James Acquisition and Development

Great St. Jim, LLC was organized in October 2015 and acquired Great St. James through a series of transactions in 2016.

The Virgin Islands government’s second amended complaint against the Epstein estate identified three parcels making up the property. The government alleged that Great St. Jim, LLC held the parcels and that Epstein was listed as a manager and member of the company.

The same complaint stated that a certificate supplied to DPNR authorized representatives of Poplar, Inc. to handle permitting transactions for Great St. Jim, LLC.

Development plans associated with Great St. James included combinations of roads, docks, homes, cottages, utility infrastructure, security facilities, work areas, solar installations, landscaping, a pool, and other structures. A plan or application establishes what was proposed. It does not establish that DPNR approved or that contractors completed every item.


The 2016 Great St. James Enforcement Proceeding

DPNR began a formal administrative enforcement proceeding against Great St. Jim, LLC in April 2016.

The agency issued Notice of Violation No. NOVA-04-16-STT on April 22 and served it on April 25. The proceeding concerned development undertaken on Great St. James without the required coastal authorization.

DPNR and Great St. Jim, LLC entered into a settlement agreement in August 2016. The dispute did not end there.

In November 2016, DPNR served a notice alleging breach of the settlement and directed the company to remove unpermitted development and structures. In December, the agency issued a notice alleging failure to cure the breach and sought enforcement of the settlement.

The contemporaneous DPNR cease and desist order instructed Great St. Jim, LLC not to proceed with further work unless authorized by Coastal Zone Management.

This was an administrative land use enforcement matter. It should not be represented as a criminal prosecution.


The Supplemental Consent Agreement

The parties later negotiated a supplemental consent agreement addressing NOVA-04-16-STT.

The released agreement in EFTA00795553 records the enforcement history, including:

  1. The April 2016 notice of violation
  2. The August 2016 settlement
  3. The November notice to cure
  4. The December notice of failure to cure
  5. Continued negotiations between DPNR and Great St. Jim, LLC
  6. A proposed $160,000 grant by Epstein affiliated Gratitude America to the St. Thomas Historical Trust for work associated with Fort Christian

The proposed supplemental agreement stated that further enforcement concerning the covered historical violations would be discontinued. It included a release and covenant not to sue regarding the matters it covered, while reserving DPNR’s authority over future violations, unknown costs, and natural resource damage.

It also expressly stated that the agreement and the company’s corrective actions would not constitute an admission of liability or unlawful conduct.

Some circulating accounts describe larger penalties, charitable payments, or returned funds. Those claims should not be treated as established unless supported by the final executed agreements, payment records, and authoritative findings concerning what occurred.


Later Permit and Inspection Disputes

The supplemental agreement did not give Great St. Jim, LLC unlimited authority to continue construction. DPNR retained enforcement power over later conduct.

Records released after Epstein’s death document continued disagreement over:

  1. Roads cut across the island
  2. Ramps and landing areas
  3. Coastal structures
  4. Jetties and shoreline work
  5. Placement of material in or near submerged lands
  6. Proposed buildings and utility systems
  7. Site access for inspection
  8. Whether existing permits covered particular work

EFTA00808732 contains correspondence concerning permit status and the need to have proper permits in place. EFTA00813272 preserves communications concerning reported construction activity on Great St. James.

DPNR issued another stop work order in December 2018. In 2019, officials continued examining whether roads, ramps, jetties, shoreline work, and other development exceeded existing approvals.

The government later alleged that Epstein’s representatives characterized requested inspections as invasions of his constitutional privacy because he regarded the entire island as his home. The allegation appears in the Virgin Islands complaint. It was not a separate judicial finding that Epstein possessed a constitutional right to exclude regulatory inspectors.


The 2019 Communications With Governor Albert Bryan Jr.

Documents released in 2026 added an important governmental accountability issue to the permit history.

Messages reviewed in reporting showed Epstein contacting Virgin Islands Governor Albert Bryan Jr. during the 2019 construction dispute. Epstein complained about enforcement, potential fines, and adverse publicity. Bryan’s messages indicated that he had discussed the matter with DPNR leadership, requested a pause while officials conferred, and asked the responsible commissioner to recuse himself or defer to existing permits.

The exchanges were reported by CNN and summarized with the underlying context. They document Epstein seeking high level political assistance in an active regulatory matter.

The messages do not by themselves establish bribery, a criminal conspiracy, or that DPNR ultimately granted an unlawful permit. DPNR Commissioner Jean-Pierre Oriol later testified that Epstein did not receive special treatment from his department.

The proper conclusion is narrower: Epstein had direct access to the governor and used that access to seek intervention in a land use enforcement dispute.


Federal Environmental Review

Federal environmental authorities also examined matters associated with Epstein’s Virgin Islands properties.

The Environmental Protection Agency’s Office of Inspector General opened an inquiry after receiving allegations concerning possible kickbacks or improper considerations connected to environmental regulation of Epstein’s properties.

The inquiry did not result in a public finding that Epstein bribed environmental regulators. A referral or inspector general investigation establishes that an allegation was examined. It does not establish that the allegation was substantiated.

Federal agencies also had potential jurisdiction over navigable waters, docks, dredging, fill, water quality, and effects on protected environmental resources. An EPA or Army Corps inspection was distinct from DPNR’s territorial permit enforcement.


Virgin Islands v. Epstein Estate

The property use and environmental record became part of the broader civil enforcement action Government of the United States Virgin Islands v. Estate of Jeffrey E. Epstein, No. ST-20-CV-014.

The government sued the estate, its coexecutors, the 1953 Trust, and multiple Epstein controlled entities in 2020.

Its allegations extended well beyond zoning. The complaint asserted claims under the Virgin Islands Criminally Influenced and Corrupt Organizations Act, trafficking laws, child protection statutes, fraud law, and other territorial provisions.

The government alleged that:

  1. Little St. James and Great St. James were used as instrumentalities of Epstein’s trafficking enterprise
  2. Great St. Jim, LLC and Nautilus, Inc. held properties used in the alleged enterprise
  3. Unpermitted construction reflected a broader pattern of disregarding Virgin Islands law
  4. Epstein’s representatives attempted to restrict regulatory inspections
  5. The territory could incur expenses to remove or remediate unlawful construction
  6. Development on Great St. James damaged environmental and historical resources

These were allegations in a civil complaint. They were not all converted into findings after a contested trial because the litigation settled.


The 2022 Virgin Islands Settlement

In December 2022, the Virgin Islands announced a settlement of its civil enforcement case against the estate, Darren Indyke, Richard Kahn, and associated entities.

Under the official settlement announcement, the defendants agreed to:

  1. Pay the Virgin Islands $105 million in cash
  2. Pay the government one half of the proceeds from the eventual sale of Little St. James
  3. Return more than $80 million in economic development tax benefits
  4. Pay $450,000 to remediate environmental damage on Great St. James
  5. Sell Little St. James and Great St. James to independent third parties
  6. Wind down Epstein affiliated business operations in the territory
  7. Provide documents supporting continuing investigations

The government stated that the environmental payment concerned damage caused when remains of historical structures associated with enslaved workers were razed during development on Great St. James.

The settlement resolved disputed claims without a trial verdict determining every allegation. It nevertheless created binding payment, sale, remediation, and document production obligations.


Sale of Little St. James and Great St. James

The estate listed the islands for sale in 2022.

In May 2023, Stephen Deckoff’s SD Investments acquired Little St. James and Great St. James for a combined $60 million. The sale and announced resort plans were confirmed by the Associated Press.

The purchase did not transfer Epstein’s criminal or civil liability to the new owner. It also did not automatically approve a resort.

Any substantial redevelopment remained subject to applicable Virgin Islands coastal, environmental, building, utility, and land use approvals. Early announcements projected a luxury resort, but the announcement of a project is not proof that permits were issued or construction completed.

The islands’ sale helped satisfy obligations arising from the estate litigation. It was not itself a forfeiture judgment following a criminal conviction.


Zorro Ranch and New Mexico State Land

Zorro Ranch consisted of privately held property together with interests in surrounding state trust land.

Released records, including the extensive state lease file in EFTA01305252, document grazing leases, land appraisals, rights of way, and communications with the New Mexico State Land Office.

EFTA00030804 contains early transaction and improvement records, including a partial assignment of a state agricultural lease and an application associated with proposed ranch improvements.

These records show that the ranch’s operational footprint was not limited to land owned outright by Epstein’s entity. They do not establish that Epstein owned all land within the area commonly described as the approximately 10,000 acre ranch.


Cancellation of the Cypress Grazing Leases

In September 2019, New Mexico Commissioner of Public Lands Stephanie Garcia Richard sent Cypress, Inc. a notice canceling two agricultural grazing leases associated with Zorro Ranch.

The State Land Office announcement stated that the office had supplied more than 400 pages of records to the New Mexico attorney general. Those records concerned approximately 1,243 acres of state trust land leased to Cypress.

The office also reported that repeated requests to enter the ranch and inspect the state trust land had gone unanswered after Epstein’s death.

Cypress initially contested the cancellation. The State Land Office maintained that it possessed legal authority to terminate the leases.

In November 2019, Cypress conceded the cancellation and abandoned its legal challenge. The State Land Office’s 2019 release archive records the contest and its termination.

This result concerned two state grazing leases. It did not transfer the entire privately owned ranch to New Mexico.


What the New Mexico Lease Case Established

The lease proceeding established that:

  1. Cypress held two state agricultural grazing leases connected with Zorro Ranch
  2. The leased land totaled approximately 1,243 acres
  3. The State Land Office sought access to inspect the public land
  4. The commissioner canceled the leases
  5. Cypress initially contested the decision
  6. Cypress later dropped the contest and accepted the cancellation

The proceeding did not establish that every structure on Zorro Ranch violated zoning law. It did not establish the truth of every allegation concerning activities at the ranch. It also did not result in a criminal conviction.

The state lease record should therefore be described as a public land use and administrative dispute, not as a comprehensive zoning judgment against Zorro Ranch.


The 2026 Zorro Ranch Investigations Are Separate

New Mexico reopened a criminal investigation concerning alleged activity at Zorro Ranch in 2026. State investigators searched the former ranch with the cooperation of its new owners.

The New Mexico House also established an investigative commission, and the attorney general later sued the United States Department of Justice for access to unredacted federal records. The New Mexico Department of Justice described that federal action as necessary to its continuing criminal investigation.

Those proceedings are not zoning cases.

They concern potential criminal conduct, government records, investigative jurisdiction, and access to evidence. They should be cross referenced with property use records because the ranch is the relevant location, but they must retain their correct legal classification.


The Palm Beach Mansion

Epstein’s residence at 358 El Brillo Way in Palm Beach was a central location in the 2005 police investigation and later criminal and civil cases.

Survivor statements, police records, search materials, photographs, and trial exhibits document the property’s layout and its use by Epstein, staff, visitors, and girls recruited to provide massages.

Those records establish the property’s evidentiary importance. They do not automatically establish zoning violations.

A reliable primary record has not been identified supporting broad claims that Palm Beach authorities brought zoning cases against Epstein for:

  1. Excessive security installations
  2. Unpermitted staff housing
  3. Interior alterations designed to facilitate abuse
  4. Detached structures used contrary to zoning
  5. Code violations discovered during the 2005 criminal investigation

Unless a permit, violation notice, code enforcement docket, or municipal order is produced, those claims should not appear as established facts.


Demolition and Redevelopment in Palm Beach

The estate sold the El Brillo Way property to developer Todd Michael Glaser in 2021.

The Town of Palm Beach Architectural Commission approved demolition, and the mansion was razed in April 2021. The demolition was a post sale land development action, not a penalty imposed on Epstein.

The former structure’s association with Epstein was a principal reason the buyer elected to demolish it, but the approval did not constitute a government finding concerning the criminal allegations.

The site was later redeveloped. Changes to the address and replacement of the residence reflected the new owner’s effort to separate the property from Epstein’s notoriety.


The Manhattan Townhouse

The townhouse at 9 East 71st Street was owned through Maple, Inc. and served as Epstein’s New York residence and office.

Federal agents searched it following Epstein’s arrest in July 2019. Survivor lawsuits and criminal proceedings repeatedly identified the property as a location of alleged sexual abuse, recruitment, meetings, and evidence storage.

Civil actions included V.E. v. Nine East 71st Street, No. 1:19-cv-07625, which named the property holding entity and other defendants.

That case involved alleged abuse and civil liability. It was not a zoning prosecution.

No primary municipal record has been identified establishing that New York City brought a zoning enforcement case against Epstein for operating the townhouse as a commercial establishment, institutional facility, staff residence, or security center. The property’s intensive use and unusual interior arrangements are not, standing alone, proof of a zoning violation.


Property Use Evidence Is Not Zoning Evidence

Survivor testimony about events at a residence can be powerful evidence in a criminal or civil case. It still does not answer the separate land use question of whether the property complied with municipal zoning.

Likewise:

  1. A locked door is not necessarily a building code violation
  2. A security camera is not necessarily an unlawful installation
  3. Staff working inside a residence does not necessarily convert it into a commercial property
  4. Frequent guests do not automatically create an institutional use
  5. A private airstrip does not necessarily lack regulatory approval
  6. A dock shown in a photograph does not prove that it was unpermitted
  7. A proposed building shown on a plan does not prove that it was constructed
  8. A property company named in a survivor lawsuit was not necessarily found liable

The land use record becomes probative when it is connected to an authenticated permit, inspection, enforcement notice, administrative decision, consent agreement, deed, lease, or judicial ruling.


What the Evidence Establishes

The available record establishes that:

  1. Epstein’s properties were generally held through separate legal entities.
  2. Little St. James accumulated extensive coastal, building, dock, utility, and environmental permit records.
  3. DPNR commenced administrative enforcement proceeding NOVA-04-16-STT against Great St. Jim, LLC in April 2016.
  4. Great St. Jim, LLC entered a settlement with DPNR in August 2016.
  5. DPNR later alleged that the company breached and failed to cure the settlement.
  6. The parties negotiated a supplemental consent agreement covering the earlier dispute.
  7. The supplemental agreement contained no admission of unlawful conduct.
  8. DPNR retained authority over future violations and previously unknown environmental damage.
  9. Permit and inspection disputes continued after the 2016 proceeding.
  10. Epstein sought assistance from Governor Albert Bryan Jr. during the 2019 enforcement dispute.
  11. The Virgin Islands incorporated construction and environmental allegations into its civil case against the estate.
  12. The 2022 settlement required $450,000 for environmental remediation on Great St. James.
  13. The estate was required to sell Little St. James and Great St. James.
  14. The islands sold for a combined $60 million in 2023.
  15. New Mexico canceled two Cypress grazing leases covering approximately 1,243 acres of state trust land.
  16. Cypress initially contested the cancellations and later abandoned the challenge.
  17. The Palm Beach mansion was demolished after review by the Town of Palm Beach Architectural Commission.
  18. Survivor cases involving the Manhattan and Palm Beach properties were not automatically zoning cases.

What the Evidence Does Not Establish

The available record does not establish that:

  1. Every structure on an Epstein property was unpermitted.
  2. Every project listed in a permit inventory was completed.
  3. Every violation alleged by DPNR was admitted by Great St. Jim, LLC.
  4. The 2016 administrative matter resulted in a criminal conviction.
  5. The supplemental consent agreement established bribery or corruption.
  6. Governor Bryan’s communications prove that an unlawful permit was issued.
  7. The EPA established that Epstein bribed environmental officials.
  8. The Virgin Islands obtained a trial verdict on every allegation in its estate complaint.
  9. New Mexico seized the entire Zorro Ranch through the grazing lease cancellation.
  10. Every building at Zorro Ranch violated county zoning.
  11. The 2026 Zorro Ranch investigation is a zoning proceeding.
  12. Palm Beach brought a verified zoning case over Epstein’s security systems or interior alterations.
  13. New York City adjudicated the Manhattan townhouse to be an unlawful commercial or institutional use.
  14. A civil complaint naming a property company proves the company’s liability.
  15. The sale or demolition of a property constitutes a finding that the building itself was illegal.
  16. A photograph of a road, dock, airstrip, helipad, or building proves its permit status.

Investigative Assessment

The documented land use record is narrower than some earlier summaries suggested.

The central verified zoning and environmental proceeding is DPNR’s enforcement action against Great St. Jim, LLC. It is supported by a notice of violation, settlement documents, cure notices, permit correspondence, and later allegations in the Virgin Islands estate litigation.

The New Mexico grazing lease cancellation is the second clearly documented property use proceeding. It concerned public land leased to Cypress, not the privately owned ranch in its entirety.

The Manhattan and Palm Beach properties were undeniably important locations in the criminal and civil evidence. Their evidentiary significance should not be converted into unsupported claims that municipal zoning agencies found the properties unlawful.

The broader significance of the property record lies in what it reveals about access and oversight. Private islands, gated residences, corporate ownership, leased buffer land, aircraft facilities, docks, and controlled transportation made regulatory inspections unusually important.

Where regulators sought access or ordered work stopped, those actions created an independent documentary record. That record can corroborate dates, structures, corporate control, construction activity, and communications with officials. It cannot, without additional evidence, prove the criminal purpose of every structure or the truth of every allegation concerning events at the properties.


Key Takeaways

  1. “Zoning and Property Use Cases” is a research category, not one formal lawsuit.
  2. The principal verified zoning proceeding involved Great St. Jim, LLC and the Virgin Islands DPNR.
  3. DPNR issued a notice of violation and pursued settlement enforcement beginning in 2016.
  4. The resulting supplemental agreement contained no admission of liability.
  5. Later construction and inspection disputes continued through 2019.
  6. Epstein directly sought the Virgin Islands governor’s help with the permit dispute.
  7. The communications raise accountability questions but do not alone prove criminal corruption.
  8. Environmental and construction allegations became part of the Virgin Islands estate litigation.
  9. The 2022 settlement required payments, island sales, and environmental remediation.
  10. New Mexico canceled only the state grazing leases connected with Zorro Ranch, not the entire ranch.
  11. Cypress contested and then accepted the grazing lease cancellation.
  12. Criminal investigations into conduct at a property are not zoning cases.
  13. The Palm Beach and Manhattan properties were central evidentiary locations, but verified municipal zoning cases concerning their alleged internal use have not been identified.
  14. Permits, plans, violations, allegations, settlements, and judgments must remain separately classified.

Related EpsteinWiki Articles

  1. Jeffrey Epstein
  2. Ghislaine Maxwell
  3. Environmental Zoning Violations
  4. New Mexico Property Legal Actions
  5. Zorro Ranch Entities
  6. Real Estate Forfeiture Actions
  7. Little St. James Property Seizure Proceedings
  8. Territory of the U.S. Virgin Islands v. Epstein Estate
  9. U.S. Virgin Islands Government
  10. Property and Location Timelines
  11. How to Read an Epstein Document

Primary Government, Court, and Property Sources

  1. Government of the Virgin Islands v. Estate of Jeffrey E. Epstein complaint
  2. Government of the Virgin Islands second amended complaint
  3. DPNR cease and desist order for Great St. James
  4. Official Virgin Islands estate settlement announcement
  5. New Mexico State Land Office Cypress lease cancellation
  6. New Mexico State Land Office 2019 proceeding archive
  7. New Mexico House Resolution 1 concerning Zorro Ranch
  8. New Mexico Department of Justice Zorro Ranch records lawsuit announcement
  9. V.E. v. Nine East 71st Street federal docket
  10. Associated Press report confirming the 2023 island sale
  11. Justice Department Epstein Library

Primary Epstein Data Evidence

  1. EFTA00299879 is an investigative evidence inventory identifying Little St. James permit, construction, dock, water, environmental, and development files. It establishes that investigators catalogued the listed records, not that every proposed project was completed or unlawful.
  2. EFTA00300105 contains material associated with the 2016 Great St. James notice of violation and settlement process.
  3. EFTA00795553 contains a supplemental consent agreement for NOVA-04-16-STT. It records the earlier enforcement history, proposed charitable grant, releases, reservations of rights, and no admission provision.
  4. EFTA00808732 contains correspondence concerning permit status and construction authorization on Great St. James.
  5. EFTA00813272 preserves communications concerning reported development activity on Great St. James.
  6. EFTA01040824 contains correspondence about payments associated with DPNR permit filings. A routine permit filing fee should not be mischaracterized as an improper payment.
  7. EFTA01305148 contains the recorded transfer of Little St. James to Nautilus, Inc. and Epstein’s sworn ownership affidavit.
  8. EFTA01305252 contains the extensive New Mexico State Land Office lease file associated with Zorro Ranch.
  9. EFTA00030804 contains early New Mexico lease assignment and improvement application records.
  10. EFTA00310887 contains property and state grazing lease documents associated with the acquisition and operation of Zorro Ranch.
  11. EFTA01266204 identifies Epstein’s principal real estate interests, holding entities, permits, improvements, fixtures, and property rights in a confidential trust document.
  12. EFTA00018778 contains the Virgin Islands government’s allegations about the property companies, construction activity, regulatory inspections, and use of the islands. It is a government pleading, not a verdict adjudicating every allegation.
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