[COURT NAME]
[COUNTY], [STATE]

[PLAINTIFF NAME], )
Plaintiff, ) Case No. [CASE NUMBER]
v. )
[DEFENDANT NAME], )
Defendant. )

MOTION FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION

NOTICE OF MOTION AND MOTION

PLEASE TAKE NOTICE that on [HEARING DATE] at [TIME], or as soon thereafter as counsel may be heard, [PLAINTIFF] will and hereby does move the Court for a temporary restraining order and preliminary injunction to [STATE RELIEF REQUESTED].

MEMORANDUM OF POINTS AND AUTHORITIES

I. Introduction

Immediate injunctive relief is necessary to prevent irreparable harm and preserve the status quo pending resolution of this action.

II. Factual Background

• Parties and dispute: [SUMMARY]
• Conduct to be enjoined: [DESCRIPTION]
• Imminent harm: [DETAILS]

III. Legal Standard

A temporary restraining order and preliminary injunction may issue where the movant shows (1) a likelihood of success on the merits, (2) irreparable harm absent relief, (3) the balance of equities favors the movant, and (4) the injunction serves the public interest.

IV. Argument

A. Likelihood of success on the merits.
[Apply facts to claim elements.]

B. Irreparable harm is imminent.
[Explain why damages are inadequate and why the harm is immediate.]

C. The balance of equities favors [PLAINTIFF].
[Compare hardships.]

D. The public interest supports injunctive relief.
[Address public considerations if applicable.]

V. Bond

[PLAINTIFF] proposes a bond of $[AMOUNT] or requests waiver based on [REASONS], as permitted by law.

VI. Requested Relief

[PLAINTIFF] respectfully requests that the Court:
1. Issue a temporary restraining order prohibiting [SPECIFIC CONDUCT].
2. Set a hearing on the preliminary injunction at the earliest practicable date.
3. Issue a preliminary injunction maintaining the status quo during the case.

CONCLUSION

For the foregoing reasons, the Court should grant the motion for temporary restraining order and preliminary injunction.

Respectfully submitted,

text
Dated: [DATE]

______________________________
[ATTORNEY NAME]
[LAW FIRM]
[ADDRESS]
[PHONE]
[EMAIL]
Attorney for [PLAINTIFF]

CERTIFICATE OF SERVICE

I certify that on [DATE], I served the foregoing Motion for Temporary Restraining Order and Preliminary Injunction on all counsel of record via [METHOD OF SERVICE], or alternatively [STATE EFFORTS TO PROVIDE NOTICE].

text
______________________________
[ATTORNEY NAME]

[PROPOSED] ORDER

The Court, having considered the Motion for Temporary Restraining Order and Preliminary Injunction, ORDERS as follows:
1. A temporary restraining order is issued prohibiting [SPECIFIC CONDUCT].
2. A hearing on the preliminary injunction is set for [DATE/TIME].
3. [PLAINTIFF] shall post a bond in the amount of $[AMOUNT], unless waived.

IT IS SO ORDERED.

Dated: [DATE]

__________________________________
[JUDGE NAME]
[STATE] Judge