Counterfeit Product Case Proposed Order Forms
Plaintiffs in cases alleging counterfeit products and joining many defendants should use the form proposed orders linked below to assist the Court in reviewing motions for: (1) temporary restraining orders; (2) preliminary injunctions; and (3) default judgments. Plaintiffs should create a redline comparision of their proposed order against the relevant form and attach it as an exhibit to their motion. A proposed order's conformity with the form does not imply that the associated motion will be granted. But plaintiffs should be prepared to explain any differences.
Judge Durkin will presumptively require a bond of $1,000 per defendant. Plaintiffs should inform the Court of any circumstances that make such a bond inappropriate.
Form of Proposed Temporary Restraining Order
Form of Preliminary Injunction
Form of Default Judgment
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