A model Verified Complaint to be used to commence an action seeking a preliminary injunction, prospective injunction, and a temporary restraining order (TRO) against a labor union's strike in violation of a no-strike obligation and a mandatory arbitration clause in a collective bargaining agreement (CBA). It is based on the US Supreme Court's exception to the Norris-LaGuardia Act's (NLA) anti-injunction provisions in Boys Markets, Inc. v. Retail Clerks Union, Local 770.