Amended complaint - PennFuture

have had to replace on their driveway, the cost of the sandbags Plaintiffs have hadto purchase to protect their property, and the value of the time Plaintiffs havespent responding to the flooding problems on their property.h) Award Plaintiffs any future damages they may sustain as a result of the floodingproblem.i) Award Plaintiffs their costs and expenses in bringing this lawsuit, includingreasonable attorneys and experts fees.j) Retain jurisdiction over this action to ensure compliance with the Court’s decree.k) Grant such other relief to Plaintiffs as the Court may deem just and appropriate.COUNT II(Medallises v. NLD, CJS DEV INC, Tripp, CDC, Inc., and CIDC-1, LLC)UNLAWFUL CHANGE IN QUANTITY OF WATER64. The preceding paragraphs are hereby incorporated as if fully set forth herein.65. Under Pennsylvania common law, a landowner may not unreasonably orunnecessarily change the quantity of water it discharges upon a lower owner.66. NLD has unreasonably and unnecessarily changed the quantity of the stormwaterfrom pre-development conditions it discharges upon the Medallis Property.67. Upon information and belief, and for the reasons described above, the acts oromissions of CJS DEV INC, Tripp, CDC, Inc., and CIDC-1, LLC, havecontributed to this change in quantity of water.68. NLD, CJS DEV INC, Tripp, CDC, Inc., and CIDC-1, LLC, are in violation ofPennsylvania common law, resulting in the impacts described above.