Such a statement may still be considered defamatory per quod if proof of actual damages to the plaintiff's reputation can be proven. Defamation: Slander and Libel.The attorneys at Lubin Austermuehle have over thirty years of experience defending and prosecuting defamation, slander libel and cyber smear lawsuits. This Preliminary Injunctive Relief Toolkit contains resources to help counsel draft and file a motion for TRO and a motion for a preliminary injunction. This article defines preliminary injunction, details its elements and the hearing process, and includes a sample motion to download. Generally, an evidentiary hearing is necessary before imposing a preliminary injunction. Vill. Of Lake in the Hills v. In Illinois, a plaintiff must file a defamation lawsuit within one year after the defamatory statement was made, so it is important act quickly.