Sheldon R. and Phyllis Milenbach, et al. - Page 11

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          during the 2 years that the Raiders were enjoined from playing              
          their games in Los Angeles:  (1) The expense of continued                   
          operation of a summer training camp in Santa Rosa, California;              
          (2) the prevention of the establishment of a Southern California            
          training facility; (3) the necessity of leasing and maintaining a           
          practice field in both Alameda County and Los Angeles County;               
          (4) the prevention of the construction of suites in the LA                  
          Coliseum, resulting in millions of dollars in lost revenue;                 
          (5) the reduced attendance at home games at the LA Coliseum;                
          (6) the decrease in season ticket sales; (7) the loss of radio              
          revenue; and (8) the expenses associated with housing,                      
          relocation, and transportation of the Raiders personnel. In the             
          supplemental brief, the Raiders based their argument for recovery           
          on Cal. Civ. Proc. Code sec. 1268.620 (West 1982).                          
               On February 23, 1987, the Raiders filed a complaint in                 
          inverse condemnation against Oakland for damages arising out of             
          the eminent domain action alleging that:                                    
               [Oakland] denied the Raiders the free and untrammeled                  
               possession and use of the property sought to be                        
               condemned and thereby preempted Raiders’ full                          
               possessory right to the enjoyment and use of the                       
               Raiders property; interference with Raiders free use                   
               and enjoyment also constituted a taking of an interest                 
               in Raiders’ property for which Raiders have not been                   
               compensated.                                                           
          As of July 28, 1986, the Raiders claimed that the damages                   
          sustained and yet to be sustained totaled in excess of                      
          $26 million.                                                                





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