Kinsey Law Offices 
Complaint For Injunction
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    Sample Only
    Use At your Own Risk
    (Name, Address Of Party or attorney)
    State Bar No: ______
    (____) _____ - ________
    Attorney for _______ (Or "In Pro Per")



COUNTY OF ________






CASE NO: _______

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Plaintiff complains and for causes of action alleges as follows:


(For ________ Against ____)


<>. Defendant__, ___ is__, and at all times herein mentioned was__, a resident__ of the City of ___, County of __, State of California.

<>. Defendant__, ___, is__, and at all times herein mentioned, was__ a Corporation organized and existing under the laws of the State of California with principle offices located at ___, in the City of ___, County of ___.

<>. Plaintiff__ is__ ignorant of the true names and capacities of defendants sued herein as DOES I through X, inclusive, and therefore sues__ these defendants by such fictitious names. Plaintiff__ will amend this complaint to allege their true names and capacities when ascertained.

<>. Plaintiff__ is__ informed and believes__ and thereon alleges__ that, at all times herein mentioned, each of the defendants sued herein was the agent and employee of each of the remaining defendants and was at all times acting within the purpose and scope of such agency and employment.

<>. Beginning on or about ___, 19__, and continuing to the present time, defendants, and each of them, wrongfully and unlawfully ___.

<>. On or about ___, 19__, and a number of times since then, plaintiff__ has__ demanded that defendants stop their wrongful conduct described above. Defendants, and each of them, have refused and still refuse to refrain from their wrongful conduct.

<>. Defendants' wrongful conduct, unless and until enjoined and restrained by order of this court, will cause great and irreparable injury to plaintiff__ in that ___.

<>. Plaintiff__ has__ no adequate remedy at law for the injuries currently being suffered in that ___ (it will be impossible for plaintiff__ to determine the precise amount of damage which __ will suffer if defendants' conduct is not restrained) (plaintiff will be forced to institute a multiplicity of suits to obtain adeauate compensation for ___ injuries.

<>. As a result of defendants' wrongful conduct, plaintiff__ has__ been damaged in the sum of $___. Plaintiff__ will be further damaged in like manner so long as defendants' conduct continues. The full amount of such damage is not now known to plaintiff__, and plaintiff__ will amend this complaint to state such amount when the same becomes known to __, or on proof thereof.


WHEREFORE, plaintiff__ pray__ judgment against defendant__ and each of them, as follows:

1. For an order requiring defendants to show cause, if any they have, why they should not be enjoined as hereinafter set forth, during the pendency of this action;

2. For a temporary restraining order, a preliminary injunction, and a permanent injunction, all enjoining defendants, and each of them, and their agents, servants, and employees, and all persons acting under, in concert with, or for them:
A. From ___;
B. To ___;

3. For damages in the sum of $___, plus damages in such further sums as may be sustained and as are ascertained before final judgment herein;

4. For attorney fees herein incurred;

5. For costs of suit herein incurred; and

6. For such other and further relief as the court deems proper.


 DATED: _______________  __________________________________________





I, ___, am a ___in the above-entitled action. I have read the foregoing ___and know the contents thereof. The same is true of my own knowledge, except as to those matters which are therein alleged on information and belief, and as to those matters, I believe it to be true.

I declare under penalty of perjury that the foregoing is true and correct and that this declaration was executed at Long Beach, California.



DATED: _________________ ___________________________________

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