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As explained by the Supreme Court, our entire jurisprudence runs counter to the notion of court action taken before reasonable notice and an opportunity to be heard has been granted both sides of a dispute. 1 As a result, restraining order applications sought ex parte require the court to serve as the absent partys advocate, triggering intense judicial scrutiny of a plaintiffs claims, the relief it seeks, and most importantly, its proffered justification for proceeding ex parte 2

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doi: 10.1016/j.wasman.2021.05.029 27 LinL.ChenC