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Exercise Extreme Caution when using many of our free forms - or any legal material. While they may provide general ideas on format & content, validity requirements can and do vary greatly from state to state. Many MUST be Properly Modified for your own location and circumstances. (Hint: If in doubt it's usually safer to include unneeded clauses than to leave out necessary ones. . . . but it's even safer to consult a competent source or use current, state specific ones like ours mentioned below.) Also, we urge people (and lawyers too) to read our Relying On Legal Info FAQ.

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We strongly suggest that you use State Specific (forms drafted for your State). U.S. Legal Forms, Inc. maintains a staff of attorneys who draft and update Forms for each State. So, visit U.S. Legal Forms for State Specific Wills, Living Wills, Power of Attorney, Real Estate, Landlord Tenant, Corporate, Affidavits, Releases and Other Forms and download your form in Word format.

__Attorney name]__
__[Address]__
__[Telephone number]__

Attorney for Plaintiff, __[name]___

_ _ _ _ _ Court, County of _ _ _ _ _ _
__[_ _ _ _ _ _ District]__

_ _ _ _ _ _ _ _ _ _ _ _ _) No. _ _ _ _ _ _
Plaintiff(s) )
vs. ) COMPLAINT FOR INJUNCTIVE RELIEF
) __[AND DAMAGES]__
_ _ _ _ _ _ _ _ _ _ _ _ _)
Defendant(s) )
_________________________)

Plaintiff, __[name]__, alleges:

1. Plaintiff is now, and at all times mentioned in this complaint has been, __[allege facts showing plaintiff's status and interest in subject of action, e.g., owner of certain described real property/shareholder of __[name of corporation]__ engaged in the business of __[specify]__]__.

2. Defendant, __[name]__, is now, and at all times mentioned in this complaint has been, __[allege facts showing defendant's status in relation to plaintiff, e.g., adjoining landowner/officer of __[name of corporation]__ engaged in the business of __[specify]__]__.

3. On or about __[date]__, and continuing to the present, defendant has wrongfully and unlawfully __[allege defendant's wrongful acts in particular as well as general course of conduct]__. __[If acts have not yet been committed, but are imminent, allege accordingly]__.

4. On or about __[date]__, and at other times between that date and the present, plaintiff has demanded that defendant refrain from committing the above acts, but defendant has refused and has threatened to
__[continue/commence]__ such acts unless immediately enjoined by this Court from doing so.

5. As a result of defendant's acts, plaintiff __[has sustained/will sustain]__ great and irreparable injury in that __[allege specific injury, showing irreparable character, e.g., specific waste, destruction, trespass, or injury to real property/facts and circumstances showing that acts constitute nuisance/loss of contracts, customers, or trade/deprivation of civil or constitutional rights]__.

6. Plaintiff cannot be fully compensated in damages, is without an adequate remedy at law because the exact amount of damage plaintiff will sustain will be difficult to determine, and __[allege other facts showing inadequacy of legal remedy, e.g., defendant's inability to respond in damages/imminent multiplicity of actions/public policy
considerations/exhaustion of legal or administrative remedies]__.

[Add if incidental damages are sought]
7. As a further result of defendant's acts, plaintiff has sustained damage in the amount of $_ _ _ _ _ _. If these acts are permitted to continue, plaintiff will be further damaged in an amount to be alleged when additional damages have been determined.

[Continue]

WHEREFORE, plaintiff demands judgment for:

1. __[State character of relief sought, e.g., temporary restraining order/preliminary and permanent injunction]__ enjoining __[name persons to be enjoined, e.g., defendant, __[his/her/its]__ agents, employees, officers, attorneys, and representatives]__ from engaging in or performing any of the following acts: __[Specify acts sought to be enjoined]__.

2. Damages against defendant in the amount of $_ _ _ _ _ _ __[and additional damages according to proof]__.

3. Costs of this action and other just relief.

Date: _ _ _ _ _ _ [Signature]
________________________
__[Typed name]__
Attorney for _ _ _ _ _ _ _ _ _

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