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242. The substantial defects Plaintiffs have discovered were caused by JNJ's and <br /> Brennan Properties' faulty workmanship and constitute a breach of JNJ's and Brennan <br /> Properties' duty of care to the Plaintiffs. <br /> 243. Plaintiffs have suffered damages as a result of JNJ's and Brennan <br /> Properties' negligence. <br /> 244. To the extent these damages can be measured, they include at least the cost <br /> of repairs necessary to correct the defects to the Property. Recovery of reasonable <br /> damages in an amount greater than $50,000 is sought. <br /> V. PRAYER FOR RELIEF <br /> WHEREFORE, Plaintiffs respectfully request that this Court enter an order and <br /> judgment in their favor and against Defendants as follows: <br /> (a) For Declaratory Judgment that the Conservation Easement is invalid, <br /> ineffective, and unenforceable against Plaintiffs; <br /> (b) For Declaratory Judgment that the Subdivision Resolution is invalid and <br /> ineffective, and that the Property and the Adjacent Land are undivided; <br /> (c) For rescission of the Purchase Agreement; <br /> (d) For an award of damages against all Defendants,jointly and severally, <br /> equal to the costs expended by Plaintiffs for repairs necessary to correct the defects of the <br /> Property in an amount greater than $50,000 to be proven at trial; <br /> (e) If rescission is not granted, for an award of damages against all Defendants, <br /> jointly and severally, equal to (i) the difference between the value of the Property <br /> unencumbered by the Conservation Easement and the value as encumbered, and (ii) the <br /> 37 <br />