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D filed a complaint for permanent injunction against P, claiming it would be irreparably damaged if P were allowed to continue building her home contrary to deed restrictions. Without notice to P, D obtained a temporary restraining order on the day the complaint was filed, prohibiting P from further construction of her residence. The court set the amount of the bond as $10. The temporary restraining order was dissolved by the trial court. The trial court determined that a preliminary injunction could not issue. P then filed a counterclaim for wrongful injunction. The trial court and the Court of Appeals determined that under Rule 65(e), P's recovery was limited to the $ 10 cash bond. P appealed.

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