Letter to client about a proposed interim injunction

Produced in partnership with Richard Clayman of Kingsley Napley and Anna O’Carroll of Kingsley Napley
Precedents

Letter to client about a proposed interim injunction

Produced in partnership with Richard Clayman of Kingsley Napley and Anna O’Carroll of Kingsley Napley

Precedents
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[Date]

[Client's name and address]

Dear [insert client name]

Re: Injunctive relief

I am writing to advise you in respect of your proposed application for an interim injunction against [name of party] in order to [insert reason for and type of injunctive relief being sought].

An injunction is an order of the court that requires a party either to do a specified act (known as mandatory injunctions) or to refrain from doing a specified act (known as prohibitory injunctions).

The aim of an interim injunction is to maintain the status quo and/or limit potential injustice in advance of a claim or issue being determined.

When considering whether to grant an injunction, the court will address whether:

  1. there is a serious question to be tried;

  2. damages are likely to be an adequate remedy in respect of any loss that might be suffered if the injunction is not granted;

  3. it would maintain

Richard Clayman
Richard Clayman

Solicitor, Kingsley Napley


Richard’s experience covers a broad range of commercial disputes, acting for claimants and defendants, often in complex and multi-jurisdictional claims. Richard has considerable experience in obtaining and resisting orders for interim remedies before the English Court, including worldwide freezing orders, injunctions, security for costs and disclosure orders.  

Richard successfully defended a number of English limited liability partnerships against an application brought under s.25 of the Civil Jurisdiction and Judgments Act 1982 by various entities owned by the Emirate of Ras Al Khaimah, which sought extensive interim relief in aid of high value proceedings before the courts of the Republic of Georgia and Ras Al Khaimah. 

Richard’s practice also encompasses a broad range of board room and shareholder disputes involving claims between partners, shareholders, directors and/or their companies or any combination thereof. Many such cases involve substantial overseas investment into the jurisdiction.

Anna O’Carroll
Anna O’Carroll

Solicitor, Kingsley Napley


Anna is a solicitor in the Dispute Resolution team at Kingsley Napley LLP.
 
Anna acts in a broad range of disputes including high value corporate and contractual disputes, multi-jurisdictional fraud cases, intellectual property, and professional negligence claims.
 
She has particular expertise in acting for domestic and international clients on complex, multi-jurisdictional, trust, estate and Court of Protection disputes.

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Jurisdiction(s):
United Kingdom

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