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121. Plaintiffs informed WPLLC and Stephenson that they expected to`be <br /> involved in the driveway planning. <br /> 122. Plaintiffs informed Gherardi, who on information and belief was conveying <br /> such information to WPLLC and Stephenson, that major water issues at the Property <br /> necessitated further evaluation of the driveway before its installation. <br /> 123. WPLLC and Stephenson failed to provide any required clarifications until <br /> after Plaintiffs brought a Motion for Preliminary Judgment now pending before the <br /> Court. <br /> 124. The limited clarifications that WPLLC and Stephenson have subsequently <br /> provided have not sufficiently satisfied Plaintiffs' concerns. <br /> 125. Plaintiffs, WPLLC, and Stephenson have not reached agreement on a final <br /> plan for the repairs and improvements. <br /> 126. WPLLC and Stephenson have threatened to carry out the work against the <br /> Plaintiffs' wishes irrespective of their failure to provide satisfactory clarifications. <br /> 127. Plaintiffs have suffered damages as a result of WPLLC's and Stephenson's <br /> breach of contract. <br /> 128. To the extent these damages can be measured, they include at least the costs <br /> expended to enforce Plaintiffs' contractual rights. <br /> 129. Plaintiffs will suffer additional and irreparable damages if and when <br /> WPLLC and its agents complete construction against Plaintiffs' wishes, and Plaintiffs <br /> may bear the cost of correcting them. Recovery of reasonable damages in an amount <br /> greater than $50,000 is sought. <br /> 20 <br />