This guide includes a template complaint with cause of action for injunction. It will not fit your circumstances exactly and must be customized.This practice note outlines the steps you should take while preparing for and conducting preliminary injunction hearings on behalf of plaintiff employers. Injunctive relief is always predicated upon showing a threat of irreparable harm and an absence of adequate legal remedies. This action is based, in substantial part, on the breach of an insurance contract concerning a. This action is based, in substantial part, on the breach of an insurance contract concerning a. DON DEFENDANT and DOES 1 through. 25, inclusive,. Defendants. Choosing whether to grant temporary injunctive relief is up to the discretion of the court. This is known as injunctive relief, and it will usually only be granted if a plaintiff meets specific legal requirements.