COMPLAINT FOR INJUNCTIVE RELIEF
Attorney for Plaintiff, _______________________
________________________ ) Case No. _________
vs. ) COMPLAINT FOR INJUNCTIVE RELIEF
) __[AND DAMAGES]__
Plaintiff, ______________________, alleges:
1. Plaintiff is now, and at all times mentioned in this complaint has been, __[state facts that show plaintiff's status and interest in subject of action, e.g., "Plaintiff is the owner of certain described real propertyï¿½/ or Plaintiff is a shareholder of _________corporation engaged in the business ofï¿½].
2. Defendant, _________________, is now, and at all times mentioned in this complaint has been, [state facts that show defendant's status in relation to plaintiff, e.g., " Defendant is the owner of certain described real propertyï¿½/ or Plaintiff is an officer __________ corporation engaged in the business ofï¿½].
3. On or about ______, and continuing to the present, defendant has wrongfully and unlawfully [state particular wrongful acts done by defendant as well as general course of conduct or if acts have not yet been committed, but are imminent, so state].
4. On or about ______, and at other times between that date and the present, plaintiff has demanded that defendant refrain from committing the above named acts, but defendant has refused and has threatened to continue such acts.
5. As a result of defendant's acts, plaintiff has sustained/will sustain great and irreparable injury in that [state specific damages that will result and why they are irreparable].
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 [state any other facts showing
inadequacy of legal remedy].
7. As a further result of defendant's acts, plaintiff has sustained damage in the amount of ________ dollars ($ ). If these acts are permitted to continue, plaintiff will be further damaged in an amount to be alleged when additional damages have been determined.
WHEREFORE, plaintiff demands judgment for:
1. State character of relief sought, e.g., temporary restraining order/preliminary and permanent injunction enjoining _______________________ from engaging in or performing any of the following acts:
2. Damages against defendant in the amount of _____________ dollars ($ ).
3. Costs of this action and other just relief.
Attorney for _______________________
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