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TO THE COURT, ALL INTERESTED PARTIES AND THEIR ATTORNEYS OF RECORD:
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Defendants, _______________herein submit their opposition to the application of Plaintiffs,
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OPPOSITION TO REQUEST FOR TRO AND PRELIMINARY INJUNCTION
1 preliminary injunction on the grounds that Plaintiffs lack standing to file this lawsuit resulting in a
2 complete lack of authority to bring the lawsuit in the first place, plaintiffs have engaged in completely
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inequitable conduct regarding the matters at issue in this case which demonstrates a complete lack of
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good faith, and as it is an ultra vires action by a non legitimate board that is acting in violation of the
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bylaws.
7 The opposition shall be based on this opposition, the attached memorandum of points and
8 authorities, the declarations of _____________ and Exhibits attached thereto, on the complete files
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and records of this action and on such other oral and/or documentary evidence as may be presented at
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the hearing on the Motion.
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14 Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
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NOTE THAT YOU SHOULD SERVE YOUR OPPOSITION BY
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HAS ORDERED OTHERWISE.
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OPPOSITION TO REQUEST FOR TRO AND PRELIMINARY INJUNCTION
1 TABLE OF CONTENTS
Page
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I. STATEMENT OF FACTS.1
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II. ARGUMENT.X
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A. PLAINTIFFS LACK STANDING AS THEY ARE NOT THE REAL PARTY IN
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INTEREST IN THAT THE ALLEGED BOARD IS NOT THE LEGITIMATE
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BOARD AS SHOWN BY THE BYLAWS AND BOARD MINUTES ..X
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B. PLAINTIFFS ARE NOT ENTITLED TO THE ISSUANCE OF A PRELIMINARY
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INJUNCTION AS THE LAW IS SETTLED IN CALIFORNIA THAT A
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PRELIMINARY INJUNCTION MUST NOT ISSUE UNTIL IT IS REASONABLY
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PROBABLE THAT THE MOVING PARTY WILL PREVAIL ON THE MERITS ..X
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15 opposition-to-request-for-temporary-restaining-order-in-
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california
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OPPOSITION TO REQUEST FOR TEMPORARY RESTRAINING ORDER AND OSC RE: INJUNCTION