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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. |
__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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