Amended complaint - PennFuture

84. The Medallises have advised the SRA that eroded material and debris from theSRA Property have entered upon the Medallis Property.85. The SRA continues to allow eroded material and debris from the SRA Property toenter the Medallis Property.WHEREFORE, Plaintiffs Grace Medallis and Robert A. Medallis respectfullyrequest that this Court:a) Order Defendant SRA to cease and desist storing debris on the SRA property andallowing it and eroded material to enter the Medallis Property.b) Award Plaintiffs their costs and expenses in bringing this lawsuit, includingreasonable attorneys and experts fees.c) Retain jurisdiction over this action to ensure compliance with the Court’s decree.d) Grant such other relief to Plaintiffs as the Court may deem just and appropriate.COUNT V(Medallises v. SRA)NUISANCE86. The preceding paragraphs are hereby incorporated as if fully set forth herein.87. A nuisance is the nontresspassory invasion of another’s interest in the use and inthe enjoyment of land.88. The storing of debris by SRA on the SRA Property invades the interest of theMedallises in the use and in the enjoyment of the Medallis Property, as describedabove.WHEREFORE, Plaintiffs Grace Medallis and Robert A. Medallis respectfully requestthat this Court: