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; <br />which Plaintiffs have suffered and will continue to suffer actual <br />damages as a result of said conduct. <br />WHEREFORE, Plaintiffs demand a judgment of this Court <br />against Defendant as follows: <br />A. Determining that the actions of Defendant in ordering <br />removal of the non-conforming dock from Plaintiffs' property was <br />unlawful and ordering lat Plaintiff be permitted to reconstruct <br />said non-conforming dock. <br />B. Determining that the actions by Defendant City were <br />arbitrary and capricious towards Plaintiffs and that Plaintiffs <br />have the right to keep their existing dock on subject property, <br />in addition to reconstructing the non-conforming dock that was <br />unlawfully removed. <br />C. Ordering that the actions by Defendant are a denial of <br />protection afforded Plaintiffs under §1983, Title 28, of the <br />United States Code; further, that Plaintiffs are entitled to <br />money damages for said violation in excess of $50,000.00. <br />D. Determining that the Ordinances and Regulations of <br />Defendant City pertaining to permissible use and construction of <br />boat docks are not enforced uniformly against against all persons <br />amounting to an equal protection violation under both Minnesota <br />and United States Constitutions; and ordering that Plaintiffs <br />have the right to keep and maintain their existing boat dock and <br />reconstruct the lawful non-conforming boat dock that was <br />unlawfully removed. <br />E. Determining that the unlawful removal of the non- <br />conforming boat dock by Defendant, together with the manner in <br />which Defendant has restricted Plaintiffs' reasonable use of <br />-8-