(B)(1) After the filing of the complaint, an application for a temporary injunction may be filed with the court or a judge of the court. Now, having opted in to ARPA, Ohio seeks a permanent injunction to prevent the Secretary from enforcing the Tax Mandate against the State.A party cannot secure a permanent injunction without winning the underlying lawsuit. No preliminary injunction shall be issued without reasonable notice to the adverse party. Section VII of this Guide also shows how to fill out these forms. While a Court is permitted to consider the four factors required for issuance of a preliminary injunction, immediacy and irreparability of harm. Plaintiff the State of Ohio, ex rel. Dave Yost, Ohio Attorney General (the "Attorney. Hiring Counsel: As you have no right to appointed counsel in a civil action, you should seek legal counsel before filing your lawsuit. It takes more than three weeks to get a preliminary injunction (sometimes much more).