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XIV. <br /> <br /> That because the Defendant has refused to issue said Building <br />Permit to Plaintiff and not allowed subdivision by the Plaintiff <br />of the property described in Paragraph 3 hereof, the Plaintiff has <br />been unable to complete building the structure on the land described <br />in Paragraph 10. <br /> <br /> XV. <br /> <br /> That the Mayor and City Council's action in refusing to issue <br /> <br />a Building. Permit is arbitrary and capricious. <br /> <br /> XVI. <br /> <br /> That as a direct and proximate result of the wrongful conduCt <br />of the Defendant herein, the Plaintiff has suffered damages· in.the <br />amount of $100,000.00. <br /> <br /> WHEREFORE, Plaintiff demands judgment against the Defendant <br /> <br />as follows: <br /> <br /> 1. Awarding Plaintiff a judgment against the Defendant in <br /> <br />the amount of $100,000.00. <br /> <br /> 2 Requiring Defendant tb permit the subdivision of' Plaintiff's <br />property as described in Paragraph 3 hereof. <br /> <br /> 3. Requiring Defendant to issue a building permit for the~ <br />structure described in·Paragraph 10 hereof. <br /> <br /> 4. For its reasonable attorney's fees incurred in this ac{ion. <br /> 5. For its costs and disbursements. <br /> <br /> 6. For such other and further relief as the Court shall <br />determine to be just and equitable. <br /> <br />BABCOCK, LOCHER, NEILSON & MANNELLA <br />Attorneys for Plaintiff <br />118 East Main Street <br />Anoka, Minnesota 55303 <br /> (612) 421-5151 <br /> <br /> .~. James M. Neilson <br /> <br />-4- <br /> <br /> <br />