Laserfiche WebLink
45. Plaintiff reasonably relied on Defendants' promises by hiring an <br />engineer and surveyor to create the Final Drainage Plan. <br />46. Defendants' breach of promises has resulted in damages to Plaintiff in <br />an amount to be proven at trial. <br />WHEREFORE, Plaintiff demands judgment against Defendants as set forth below. <br />Fourth Claim for Relief <br />(Trespass) <br />47. By this reference, Plaintiff repeats and incorporates the averments <br />contained in Paragraphs 1 through 46 of the Complaint as fully as if set forth herein <br />verbatim. <br />48. While Defendant was in possession of the Property, Defendant or their <br />agents intentionally imported to the Property fill material not authorized by nor in <br />compliance with the ADCO Permit or MLR Permit. <br />49. Plaintiff did not consent to Defendant's or its agent's entry and deposit <br />of the noncompliant fill material upon the Property. <br />50. Plaintiff has notified Defendant that the fill material does not comply <br />with the ADCO permit or MLR Permit. <br />51. The noncompliant fill material remains on the Property. <br />52. Defendant's trespass as described above has caused Plaintiff damages <br />in an amount to be established at trial. <br />53. Plaintiff demands trial to a jury of all issues so triable. <br />Demand for Judgment <br />WHEREFORE, Plaintiff respectfully requests that judgment enter in its favor <br />and against Defendant for: <br />a) Damages in an amount to be proven at trial; <br />b) Pre- and post -judgment interest; <br />c) Plaintiffs attorney's fees and costs; and <br />d) Such other and further relief as the Court deems just and appropriate. <br />7 <br />