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for not enforcing their ordinances and/or for Defendant not following the variance application process required. 109. Due to Defendant's failure to follow the law, the Restrictive Covenant is without any force or effect, and Plaintiffs are aggrieved by Defendant's decision to not administratively terminate the Restrictive Covenant, and are entitled to have the decision reviewed by this Court. 110. Plaintiffs' will be irreparably harmed by the actions of Defendant, and aze entitled to declaratory relief, requiring that Plaintiffs' application be approved and allow Plaintiffs to build on the Lake Parcel in accordance with their application. COUNT XIV ATTORNEYS FEES 111. Plaintiffs restate and reallege paragraphs l through I 10 of the Complaint. 112. As a result of the actions and omissions of Defendant, Plaintitfs have been required to retain the law office of Wilkerson& Hegna, PLLP. I13. Based on the foregoing, Plaintiffs are entitled to recover all costs incurred in connection with this action, including reasonable attorney's fees. WHEREFORE,Plaintiffs prays for the following relief: a. That the Court order that a writ of mandamus issue, compelling Defendant to terminate the Restrictive Covenant, approve Plaintiffs' application and deciare the Lake Parcel buildable and/or commence condemnation proceedings for its taking of property without just compensation, including the denial of reasonably convenient and suitable access as a result of the ]ift station; b. That the Court award Plaintiffs damagcs in excess of$50,000.00 suffered as a consequence of the City's violation of the United States Constitution; c. A declaratory judgment regarding the parties' rights and obligations related to the Restrictive Covenant; d. A declaratory judgment regarding Defendant's authority to exact restrictive covenants through special lot c�mbination agreements; 12