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__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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