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Thanks. Where the plaintiff can file lispendens (lis pendens ?). In court or with a title company, or county etc?
For the other option, where the plaintiff can get injunction ? I assume to file in the county. Will the defendant counter sue the plaintiff for damage?
Can the plaintiff do both before the court reach judgement? I think the informatiion/option you mentioned in very interest to the plaintiff.
You mentioned "To get an injunction, you have to file a Motion for Temporary Restraining Order with the judge, and lay out those elements.."
Can the plaintiff file a motion even when the plaintiff hasn't accomplished serving summons (because defendant does not coorporative)? if so, is the judge likely to dismiss that request? Suppose the plaintiff succeed in getting the injunction, he/she can send it to county to record that, right?
In terms of filing lis pendens, I think as long as the plaintiff has good ground in lawsuit, the risk of being counter sued is small. Anyway, nothing is certain.
Once the Complaint is filed, a plaintiff can do an Ex Parte Motion for Temporary Restraining Order, which means that the defendant isn't notified until after the fact. It's better to notify him and give him the chance to respond, but if you can't, because he's avoiding service, the judge might agree to hear the Motion. Usually, if the judge denies an ex parte restraining order on the grounds that the other party needs to be notified, you can just refile it as a regular, non-ex parte motion, and send the other party a copy.