Amended complaint - PennFuture

50. Since construction of Tripp Park began, high volumes of water and erodedmaterial and debris have flowed toward and entered upon the Medallis Propertyduring storm events.51. The combination of overflow of the storm drainage facilities in the 1200 Block ofPierce Street coupled with resulting inundation of the Medallis Property constitutea dangerous condition which created and continues to create a reasonablyforeseeable risk of the kind of harm which the Medallises have suffered andcontinue to suffer.52. The Medallises must sandbag their property during storm events to protect theirhome from stormwater runoff, eroded material and debris.53. The Medallises have installed five to six tons of gravel on their driveway over thelast several years to replace the material that has been washed away bystormwater runoff.54. The flooding problems have reduced the estimated market value of the MedallisProperty.55. The Medallises live in constant fear that their property and home will be damagedduring a storm event.56. The Medallises live in constant fear that their persons will be injured during astorm event.57. Plaintiffs’ remedies at law are inadequate, because damages alone will not renderPlaintiffs economically whole.58. Plaintiffs will suffer irreparable harm if their prayer for injunctive relief is notgranted.