Complaint for Injunctive Relief

Complaint for Injunctive Relief

IN THE COURT OF

(County), (State)

PLAINTIFF
(Name of Plaintiff)

V. CAUSE NO.

DEFENDANT
(Name of Defendant)

COMES NOW (Name of Plaintiff), Plaintiff in the above-styled and numbered cause, and files this Complaint against Defendant, (Name of Defendant), and in support thereof would show unto the Court the following matters and facts:

1. Plaintiff is an adult resident citizen of

2. Defendant is an adult resident citizen of

3. [State facts showing that Plaintiff has a property right that can be protected by injunctive relief, such as: Plaintiff is the lessee of that certain property located at

(street address, city, county, state, zip code) and being more particularly described in Exhibit A attached hereto and made a part hereof].

4. Beginning on or about (date), and continuing to the present time, Defendant wrongfully and unlawfully, in violation of (cite applicable statute or refer to relevant contract),

(Specify conduct of Defendant that constitutes an interference with a property right of Plaintiff, such as: began entering onto the above-described property stating that Plaintiff’s lease had expired and that Plaintiff must vacate the property immediately so that Plaintiff could get the property ready for a new tenant).

5. Said lease has not expired and a true and correct copy is attached as Exhibit B and made a part hereof. On or about (date), Plaintiff made demand that Defendant cease the wrongful conduct described above, but Defendant refused and continues to refuse to cease the wrongful conduct. (Attach any written demand as an Exhibit).

6. The wrongful conduct of Defendant, unless restrained and enjoined by an order of this Court, will cause great and irreparable harm to Plaintiff, in that

(e.g., Defendant's presence and activities on the property interfered and continue to interfere with Plaintiff's quiet enjoyment of the property, and caused and continue to cause Plaintiff great emotional stress).

7. Plaintiff has no adequate remedy at law for the injuries Plaintiff has suffered and will continue to suffer in the future unless Defendant's wrongful conduct is restrained and enjoined.

Wherefore, Plaintiff requests:

1. Issuance of a temporary restraining order restraining Defendant from

(e.g., entering Plaintiff’s property in violation of the lease);

2. Issuance of a preliminary injunction enjoining Defendant from

(e.g., entering Plaintiff’s property in violation of the lease) during the pendency of this action;

3. On a final hearing, Defendant be permanently enjoined from

(e.g., entering Plaintiff’s property in violation of the lease);

4. Plaintiff receive costs and expenses incurred in the action; and

5. Plaintiff receive such other and further relief as the court deems proper.

Witness my signature this the day of , 20.

STATE OF

COUNTY OF

Personally appeared before me, the undersigned authority in and for the jurisdiction aforesaid, the within-named (Name of Plaintiff) who, being by me first duly sworn according to law, states on oath that the allegations of the above and foregoing Petition are true and correct as therein stated and set forth.