__Attorney name]__
__[Telephone number]__

Attorney for Plaintiff, __[name]___

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

_ _ _ _ _ _ _ _ _ _ _ _ _  )   No. _ _ _ _ _ _
vs.                                                        )COMPLAINT FOR INJUNCTIVE RELIEF
                                                                          )__[AND DAMAGES]__
_ _ _ _ _ _ _ _ _ _ _ _ _  )
_________________________  )

     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
     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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Legal Forms : Set Two