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COUNT II <br /> BREACH OF CONTRACT <br /> 48. Plaintiffs' restate and reallege paragraphs 1 through 47 of the Complaint. <br /> 49. Pursuant to the Restrictive Covenant with Defendant in connection with the <br /> Property and based upon the facts alleged above, Plaintiffs had a valid and <br /> enforceable agreement and expectations with Defendant regarding the <br /> circumstances that would warrant termination of the agreement. <br /> 50. As a direct and proximate result of Defendant's actions and omissions in denying <br /> Plaintiffs' application, Defendant breached the agreement with Plaintiffs and <br /> subsequently, Plaintiffs has been damaged in an amount to be proven at trial, but <br /> reasonably believed to be in excess of$50,000.00. <br /> COUNT III <br /> EQUITABLE RELIEF <br /> 51. Plaintiffs restate and reallege paragraphs 1 through 50 of the Complaint. <br /> 52. Plaintiffs are entitled to have and did have an enforceable reasonable expectation <br /> of honesty, integrity and reasonable conduct by Defendant in its enforcement of <br /> the Restrictive Covenant. <br /> 53. Plaintiffs had an enforceable reasonable expectation that the Restrictive Covenant <br /> was for the sole purpose of allowing Plaintiffs predecessor-in-interest to continue <br /> using her dock and not to bar future development of the Lake Parcel; Defendant <br /> has violated this reasonable expectation. <br /> 54. Plaintiffs are entitled to equitable relief, including but not limited to, the <br /> termination of the Restrictive Covenant and approval of Plaintiffs Subdivision <br /> Application and building plans. <br /> COUNT IV <br /> SPECIFIC PERFORMANCE <br /> (IN THE ALTERNATIVE) <br /> 55. Plaintiffs restate and reallege paragraphs 1 through 54 of the Complaint. <br /> 56. Defendant and Plaintiffs predecessor-in-interest entered into a valid, binding <br /> agreement to allow Plaintiffs' predecessor-in-interest to continue use of her dock. <br /> 6 <br />