BRIEF IN SUPPORT OF
DEFENDANT'S MEMORANDUM IN OPPOSITION TO
PLAINTIFF'S MOTION FOR
Plaintiff has not demonstrated that there is any likelihood that they will succeed on the merits of the action.
Plaintiff has not demonstrated that irreparable harm (or any harm, for that matter) could result from the Court's failure to issue an injunction.
Plaintiff has not demonstrated that these proceedings have any impact on the public interest whatsoever.
Plaintiff has not demonstrated that there is any possibility of substantial harm (or any harm, for that matter) to others.
In short, Plaintiff has not established any of the factors that the Sixth Circuit has held as essential considerations in determining whether a preliminary injunction should be issued.
Plaintiff's brief is riddled with inaccuracies, misrepresentations, half-truths, and unsubstantiated allegations. There is so little substance to their motion that it is obvious that Plaintiff's primary objective is to harass me with their superior resources rather than to prevail on the merits of their position.
I respectfully request that Plaintiff's Motion for Preliminary Injunction be denied. In fact, if it is within the prerogative of the Court, I also request that Plaintiff's frivolous complaint be dismissed in its entirety, so that Plaintiff will not be able to waste any more of my time (or that of the Court).
2661 Midway Road, #224-225
Carrollton, TX 75006
Dated: October 4, 2001