Greg McAllister, left, and Rogge Dunn, right, partners with Rogge Dunn Group. Courtesy photos

One key to winning a successful Temporary Restraining Order (TRO) is understanding your client's goals. Clients can be excessively emotional about a departing executive or "lift out" of a team of employees. Often, they make decisions based on emotion, not common sense business solutions. The first order of business is to get your client to focus on their end game so you can achieve their goals cost-effectively.

For example, does your client truly want to stop someone from competing or soliciting clients or employees, or extract a license fee, or merely have the departed employee cease using trade secrets?