Laserfiche WebLink
I FIRST COUNT <br /> 2 Temporary Restraining Order, Preliminary Injunction and Permanent Injunction <br /> (Against all Defendants) <br /> 3 <br /> 4 39. Plaintiffs incorporate by reference the allegations set forth in paragraphs I to 38 <br /> as though fully set forth herein. <br /> 5 <br /> 6 40. Defendants' wrongful conduct in publishing false and misleading information <br /> 7 regarding Plaintiffs to Plaintiffs' neighbors, will cause great and irreparable injury to Plaintiffs i <br /> 8 <br /> that their reputation in the community will be irreparably harmed if Defendants are not restraine <br /> 9 <br /> as requested; the damages that Plaintiffs have and will continue to suffer will be difficult t <br /> 10 <br /> quantify; and Defendants' actions will continue to erode the good will that Plaintiffs have built i <br /> I1 <br /> the Lodi community and the greater dairy community through their own considerable expens <br /> and efforts. <br /> 12 <br /> 13 <br /> 41. Plaintiffs have no adequate remedy at law for the injuries currently being suffere <br /> 14 or that are threatened in that the damage to its reputation in the community can not be easil <br /> 15 quantified. Pecuniary compensation alone will not afford adequate relief for the loss o <br /> Plaintiffs' good will and reputation. <br /> 16 <br /> 17 42. As a proximate result of Defendants' wrongful conduct, Plaintiffs have bee <br /> 18 damaged and will be further damaged in a like manner so long as Defendants' conduct continues. <br /> 19 The full amount of this damage is not yet known to Plaintiffs, and Plaintiffs will amend thi <br /> 20 complaint to state this amount when the same becomes known to it or on proof of damages. <br /> 21 Such damages are to be determined at trial in anamount according to proof. <br /> WHEREFORE, Plaintiffs pray for relief as set forth below. <br /> 22 <br /> SECOND COUNT <br /> 23 Libel Per Se <br /> 24 (Against all Defendants) <br /> 25 43. Plaintiffs incorporate by reference the allegations set forth in paragraphs 1 to 42 <br /> 26 as fully set forth herein. <br /> 27 44. From the face of the Fact Sheet it appears that this document was published an <br /> 28 distributed by Genesis, DeArth and Coldani. The header of the Fact Sheet lists Coldani's contac <br /> 1ERUM,CRAB7FREE <br /> g <br /> COMPLAINT FOR TEMPORARY RESTRAINING ORDER,PRELIMINARY AND PERMANENT <br /> INJUNCTION,LIBEL PER SE,AND LIBEL PER QUOD <br />