Pursuant to Rule 65(b) of the State Rules of Domestic Relations Procedure, John Doe moves this Court to order Jane Doe to be preliminarily enjoined from using the approximately $XX,000 which she removed from the couple's joint checking account without his knowledge.  The account contained monies solely from the earnings of John Doe, and not monies from Jane Doe.

       In support of this Motion, John Doe states that, without the relief hereby applied for, he would suffer irreparable harm that is not capable of remediation by a final judgment in law or equity in that Jane Doe, not having worked though able to do so, has earned no monies of her own during the past six years.

       John Doe states further that there is a likelihood that he will prevail on the merits of this action at trial . . .

       Moreover, John Doe states further that when there is a division of the assets of the couple, $XX,000 is [choose an adjective that is appropriate for your court; see the note below)] in excess of the amount that would be Jane Doe's share of those assets.

       Finally, the risk of such irreparable harm in light of the chances of success on the merits by John Doe outweighs the probable harm to and the likelihood of prevailing on the merits of Jane Doe.

       An affidavit in support of this Motion is attached.

       A proposed order is attached.

                                               Respectfully submitted,
                                               John Doe, pro se

Date:                                       _______________________________
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