TRO / PRELIMINARY INJUNCTION EVIDENTIARY CHECKLIST (NEW YORK)

• State Rule References: CPLR Article 63 (temporary restraining order and preliminary injunction) and CPLR 6312 (undertaking), plus any local rule requirements.
• Declarations/Affidavits: Fact declarations covering likelihood of success elements; harm, timing, authenticity of exhibits.
• Documents/Exhibits: Contracts, correspondence, screenshots, technical logs, public filings, photos, key dates timeline.
• Irreparable Harm Proof: Non-compensable harms (loss of goodwill, trade secrets, constitutional rights), why damages inadequate, immediacy.
• Notice / Ex Parte Justification: Proof of notice attempts; explain why ex parte if sought.
• Bond Proposal: Calculation and rationale for bond; waiver argument if appropriate.
• Relief Specificity: Narrowly tailored order language; avoid overbreadth; include carve-outs.
• Expedited Discovery Need: Scope, proportionality, proposed schedule.
• Jurisdiction/Venue: Personal jurisdiction facts; venue facts; service status.
• Public Interest / Equities: Facts supporting balance; third-party impacts.
• Compliance With Local Rules: Page limits, chambers copies, certification requirements, meet-and-confer status.
• Proposed Order: Ready-to-file with blanks filled; time-limited TRO expiration; hearing date slots.
• Service Plan: Method/timing; alternative service if needed; ECF notice sufficiency.
• Hearing Materials: Binder/compendium; demonstratives; witness list (if evidentiary hearing).
• Post-Order Compliance: Monitoring plan; communication to client/ops; contempt/enforcement readiness.