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Amended complaint - PennFuture

Amended complaint - PennFuture

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) Order Defendants NLD, CJS DEV INC, Tripp, CDC, Inc., and CIDC-1, LLC, tostudy or cause to be studied remedies to the flooding problem on the MedallisProperty, including those that return the site of Tripp Park as closely as possibleto its pre-development hydrologic conditions and do not merely shift the burdento other downgradient properties or cause harm to the environment.c) Order Defendants NLD, CJS DEV INC, Tripp, CDC, Inc., and CIDC-1, LLC, toimplement or cause to be implemented remedies to the flooding problem on theMedallis Property, including those that return the site of Tripp Park as closely aspossible to its pre-development hydrologic conditions and do not merely shift theburden to other downgradient properties or cause harm to the environment.d) Enjoin Defendants NLD, CJS DEV INC, Tripp, CDC, Inc., and CIDC-1, LLC,from seeking any approval of additional phases for Tripp Park until such time asthey resolve the flooding problem on the Medallis Property.e) Enjoin Defendants NLD, CJS DEV INC, Tripp, CDC, Inc., and CIDC-1, LLC,from seeking any permits or approvals in connection with Tripp Park until suchtime as they resolve the flooding problem on the Medallis Property.f) Enjoin Defendants NLD, CJS DEV INC, Tripp, CDC, Inc., and CIDC-1, LLC,from seeking the return of any corporate bond or other security posted inconnection with Tripp Park until such time as they resolve the flooding problemon the Medallis Property.g) Award Plaintiffs their past damages sustained as a result of the flooding problem,including but not limited to, the reduced estimated market value of the MedallisProperty that the flooding problems have caused, the cost of the gravel Plaintiffs

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