Opening Memorandum of Law in Support of Motion for Temporary Restraining Order and Preliminary Injunction

• Author: Kenneth L. Dorsney
• Pages: 855-865

Opening Memorandum of Law in Support of Motion for

Temporary Restraining Order and Preliminary Injunction

IN THE UNITED STATES DISTRICT COURT

[Name of District]

[DISTRICT COURT CAPTION]

PLAINTIFF’S OPENING MEMORANDUM OF LAW IN

SUPPORT OF ITS MOTION FOR A TEMPORARY

RESTRAINING ORDER AND A PRELIMINARY INJUNCTION

[Insert Table of Contents]

[Insert Table of Authorities]

This is Plaintiff’s (also referred to herein as “Brand”) memorandum supporting its

manufacturing, importing, or flooding the market with its generic [type of drug] product

claim 1 of U.S. Patent No. 1 (“the ’001 patent”).

I. INTRODUCTION

Date

Product”) that FDA approved on [Date].” [Cite]. Consequently, Brand has no choice but

launch quantities of its ANDA Product. Brand further respectfully requests a preliminary

status quo until this Court issues its decision on the merits of

irrespective of whether the Court has adequate time to render its decision. Brand submits

courts.

When faced with similar circumstances in In re Cyclobenzaprine Hydrochloride

Extended-Release Capsule Patent Litig.,

855

A-37

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