Complaint with Preliminary Injunction
Republic of the Philippines
____________ Judicial Region
________________ TRIAL COURT
Branch _____, _____________, _____________
______________________,
Plaintiff,
-versus-
______________________,
Defendant.
x - - - - - - - - - - - - - - - - - - - - - - - - -x
Civil Case No ____________________
FOR: _____________________________
COMPLAINT
Plaintiff, by the undersigned counsel respectfully states that:
Plaintiff Juan tamad, of legal age, residing at 22 San Miguel St. Manila; while defendant Maria Makiling is of legal age, residing at 42 San Antonio St. Manila;
Plaintiff is engaged in the exclusive distribution of Nike products in the Philippines;
Defendant is also engaged in the sale of Nike products in the Phillipines;
As a result of defendants acts , plaintiff suffered damage amounting to P500,000 a month starting January 20, 2010;
Defendant continues to commit the act of illegally interfering with the agreement between plaintiff and Nike;
Plaintiff is entitled to the relief demanded in whole or part, such relief consists in the discontinuing of the acts complained of for a limited time or perpetually;
Plaintiff hereby applies for a writ of preliminary injunction to restrain the defendant from the act herein complained of, and for the purpose offers a bond in such sum this Honorable Court may fix;
PRAYER
WHEREFORE it is respectfully prayed that, after due notice and having a preliminary injunction be issued forthwith to restrain defendant from doing the act complained of, to cease and desist from selling products of Nike in the Philippine, and that after trial, said injunction be made permanent, with costs and such orders which are deemed equitable.
City of Manila March 3 2010.
(Sgd.) _____________________________
Counsel for Plaintiff