The common want following in the Rafter/Pershing Square Bill Ackman case, 14-740C, for plaintiff and for Fannie
Just compensation & damages, disgorgement, equitable restitution or other appropriate relief for the United States’ breach of contract
PRAYER FOR RELIEF WHEREFORE, Plaintiffs respectfully pray for an order and judgment:
a. On Claim I, awarding Plaintiffs just compensation under the Fifth Amendment for Case 1:14-cv-00740-MMS Document 16-1 Filed 08/17/15 Page 44 of 49 the Government’s taking of their property, in an amount to be determined at trial;
b. On Claim II, awarding Fannie Mae just compensation under the Fifth Amendment for the Government’s taking of its property, in amount to be determined at trial;
c. On Claim III, awarding the Fannie Mae damages for the Government’s illegal exaction of its money, in amount to be determined at trial;
d. On Claim IV, V, and VI, awarding Plaintiffs damages, disgorgement, equitable restitution or other appropriate relief for the United States’ breach of contract, in amount to be determined at trial;
e. Awarding Plaintiffs the costs and disbursements of this action, including reasonable attorneys’ and experts’ fees, costs and expenses; and
f. Granting such other, further and different relief as this Court deems just and proper.
Have you read the Bhatti/Rafter filings? What do they require?