MOTION FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION
1. INTRODUCTION AND RELIEF REQUESTED
Plaintiff [NAME] moves under Fed. R. Civ. P. 65 for (a) a temporary restraining order and (b) a preliminary injunction to [STATE RELIEF], supported by the accompanying memorandum, declarations, and exhibits.
2. FACTUAL BACKGROUND
- Parties and dispute: [SUMMARY]
- Harm at issue: [DESCRIBE IMMEDIATE HARM]
- Timeline of events: [KEY DATES]
3. LEGAL STANDARD (RULE 65)
- Likelihood of success on the merits.
- Irreparable harm absent relief.
- Balance of equities favors movant.
- Injunction serves the public interest.
4. APPLICATION OF FACTS TO STANDARD
Likelihood of Success
[APPLY FACTS TO CLAIM ELEMENTS]
Irreparable Harm
[DETAIL NON-COMPENSABLE HARM; DELAY EXPLANATION]
Balance of Equities
[WHY HARDSHIP TO MOVANT OUTWEIGHS OPPOSING PARTY]
Public Interest
[PUBLIC INTEREST RATIONALE]
5. BOND
Under Rule 65(c), Plaintiff proposes a bond of $[AMOUNT] or requests waiver based on [REASONS].
6. NOTICE AND SERVICE
State whether notice was given or explain why ex parte relief is warranted.
Method/date of notice to Defendant(s): [DETAILS].
7. REQUESTED ORDERS
- Issue a TRO enjoining [CONDUCT].
- Set a preliminary injunction hearing on or after [DATE].
- Allow expedited discovery (if needed): [SCOPE/TIMELINE].
- Any other relief the Court deems proper.
8. CONCLUSION
Grant the requested TRO and schedule a preliminary injunction hearing.
Respectfully submitted,
text
Dated: [DATE]
______________________________
[ATTORNEY NAME]
[LAW FIRM]
Attorneys for Plaintiff [NAME]
[// GUIDANCE: Attach proposed order, declarations with exhibits, TRO/PI checklist, and certificate of service. Comply with page limits and emergency hearing procedures.]