§ FORM 16 APPLICATION FOR PRELIMINARY INJUNCTION

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FORM 16. APPLICATION FOR PRELIMINARY INJUNCTION

    [Caption and signature block as in Form 1]

    Pursuant to Rule 65A of the Utah Rules of Civil Procedure, plaintiff moves the court for a preliminary injunction enjoining defendant from continuing use plaintiff's property, from interfering with plaintiff's business relationships, and from using any of plaintiff's trade secrets and proprietary information.

    Plaintiff's Application is based on the following grounds:

    1. Injunctive relief is an appropriate legal remedy to enjoin the breach of an enforceable agreement.

    2. Plaintiff will suffer irreparable harm unless the court issues a preliminary injunction enjoining defendant from interfering with plaintiff's business and plaintiff's customer relationships.

    3. Plaintiff will suffer irreparable harm unless the court issues a preliminary injunction enjoining defendant from disclosing, revealing, or using any of plaintiff's trade secrets or confidential information.

    4. The threat and injury to plaintiff outweighs whatever damage injunctive relief may cause defendant.

    5. Issuance of injunctive relief will not be adverse to the public interest.

    6. There is a substantial likelihood that plaintiff will prevail on the merits of the claims, or the case presents serious issues which should be the subject of further review and litigation.

    This motion is supported by an accompanying memorandum of points and authorities and by the pleadings on file with the court.