Sample of Georgia Complaint for Injunctive Relief
The following is a reproduction of an actual pleading filed in a business dispute lawsuit to enjoin the other party from continuing its unlawful acts.
IN THE SUPERIOR COURT OF FULTON COUNTY
STATE OF GEORGIA
Plaintiff Corporation, Inc., )
Plaintiff, )
)
v. ) CIVIL ACTION
)
Defendant ) FILE No.
COMPLAINT FOR INJUNCTION AND TEMPORARY RESTRAINING ORDER
Plaintiff files this Complaint and shows the following:
1.
Defendant is a resident of Fulton County, Georgia, and is subject to the jurisdiction of this Court.
2.
Attached hereto as Exhibit 1 is a true and accurate copy of an agreement between Plaintiff and Defendant. Exhibit 1 is incorporated herein for all purposes by this reference. Despite the existence of a valid and enforceable agreement prohibiting Defendant from “soliciting or taking any action to take customers away from XXX ,” Defendant has contacted numerous XXX customers and attempted to persuade them to not do business with XXX . Upon information and belief, Defendant continues this wrongful conduct.
3.
As shown from the facts contained herein, unless defendant is immediately restrained from contacting Plaintiff’s customers, plaintiff will suffer immediate and irreparable injury in that some customers have stated they will use Plaintiff’s competitors instead of Plaintiff after talking to Defendant and other customers will do the same.
4.
Attached hereto is the certificate of plaintiff’s attorney showing efforts to give notice and reasons why notice should not be required.
WHEREFORE, plaintiff prays for the following:
That the Court issue a temporary restraining order prohibiting defendant from communicating with any XXX customers or companies that appeared on any customer lists while Defendant was employed by Plaintiff;
That the Court set down at the earliest possible time a hearing on an interlocutory injunction in this cause;
That upon said hearing in this cause that the Court issue an interlocutory injunction prohibiting defendant from communicating with any XXX customers or companies that appeared on any customer lists while Defendant was employed by Plaintiff;
That upon a final hearing in this cause, that said interlocutory injunction be made permanent;
For such other and further relief that the Court deems just and proper under the circumstances.
This _____ day of _________, 2010.
Respectfully submitted,
__________________
Robert J. Fleming
Georgia Bar No. 263475
Attorney for Plaintiff
Katz Stepp Wright & Fleming LLC
2260 Resurgens Plaza
945 East Paces Ferry Road N.E.
Atlanta, Georgia 30326
(404) 923-7497
IN THE SUPERIOR COURT OF FULTON COUNTY
STATE OF GEORGIA
Plaintiff Corporation, Inc., )
Plaintiff, )
)
v. ) CIVIL ACTION
)
Defendant ) FILE No.
VERIFICATION
Personally appeared before me, an officer duly authorized to administer oaths, came Ivonne Cranford who states under oath that she is the authorized corporate representative of the plaintiff named in the above and foregoing Complaint and that the facts contained within said Complaint are true and correct.
_____________________________
AAA Representative
Sworn to and subscribed before me this
____________ day of January, 2010.
_________________________
Notary Public
My Commission Expires:
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