__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 _ _ _ _ _ _ _ _ _
Return to Table of Contents for
Legal Forms : Set Two