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114. Orono did not provide just compensation or indeed any compensation for <br /> the taking of Plaintiffs' Property. <br /> 115. Orono's demand to have the Conservation Easement granted to Orono, and <br /> Orono's subsequent acceptance of the granted Conservation Easement, violates the <br /> takings clauses of the United States and Minnesota Constitutions. <br /> 116. Plaintiffs have suffered damages as a result of Orono's unconstitutional <br /> taking with respect to the Property. <br /> 117. To the extent these damages can be measured, they include at least the <br /> difference between the value of the Property unencumbered by the Conservation <br /> Easement and the value as encumbered together with the costs and fees associated with <br /> enforcing Plaintiffs' constitutional rights. Recovery of reasonable damages in an amount <br /> greater than 550,000 is sought. <br /> COUNT IV (WPLLC and Stephenson) <br /> Breach of Contract with Respect to Consultation on Driveway <br /> 118. Plaintiffs restate and re-allege all preceding paragraphs of this Complaint <br /> as if fully set forth herein. <br /> 119. The Purchase Agreement is a contract between Plaintiffs as buyers and <br /> WPLLC and Stephenson as sellers. <br /> 120. The Purchase Agreement incorporated a binding addendum requiring <br /> WPLLC to consult with Plaintiffs and clarify its plans for the driveway, septic system, <br /> surrounding landscaping, and as to overall costs for splitting the lot and <br /> repairs/improvements needed "to the buyers [sic] satisfaction." <br /> 19 <br />