Motion for Temporary Restraining Order

              IN THE CIRCUIT COURT GREENE COUNTY MISSOURI


Marc Perkel - pro se              )
         plaintiff,               )
                                  )
vs.                               )  No. 197CC0170
                                  )
William A. Wear Jr.               )
James R. Sharp                    )
The Law Firm of Wear and Sharp    )
Vicki Stringfellow                )
Donald A. Duncan - pro se         )
The Law Firm of Turner, Reid,     )
Duncan Loomer and Patton, P.C.,   )
         defendants,              )


                   MOTION FOR PRELIMINARY INJUNCTION
                   =================================

COMES NOW, Plaintiff Marc Perkel and asks the court for an injunction to
stop execution of final judgement in the Greene County divorce case of
Perkel v. Perkel, the subject of this suit. In support of his motion,
Plaintiff states:


1) On January 15th 1997 Plaintiff filed this lawsuit as an independent
   action in equity attacking final judgement based on rule 74.06 for
   fraud upon the court. On June 2nd 1997 the pleading was amended.


2) If the defendants are allowed to execute their judgement it will
   cause the Plaintiff immediate and irreparable harm. Defendants are
   attempting to sell off real estate that rightfully belongs to the
   Plaintiff and are taking money owed to the Plaintiff's corporation.


3) An injunction would maintain the status quo.


4) As you can see from the pleading and the evidence that the facts are
   in the record proving that the defendants committed fraud upon the
   court. Thus the Plaintiff is likely to succeed on the merits.


5) The defendants have made several questionable maneuvers to
   circumvent the Missouri Rules of Court in order to avoid answering
   the pleading. Defendants Wear, Sharp, and Duncan are in violation of
   Missouri Rule 3.7 (Lawyer as Witness) and Rule 1.7 (Conflict of
   Interest) by attempting to improperly represent codefendants,
   witnesses and multiple defendants. Wear and Sharp's lawyer, Mr.
   Duncan has filed a frivolous motion to dismiss in order to allow the
   defendants to execute a judgement obtained by fraud upon the court.
   They've taken unfair advantage of the delay in appointing a special
   judge in order to attempt to execute judgement. In light of these
   violations of the rules, Since it's been 6 months since this action
   was filed, Plaintiff contends it would be fair to issue an injunction
   until this case can be heard at trial.


6) Since the court is likely to grant the defendants several favors it
   is only fair that the plaintiff get something too.



WHEREFORE, Plaintiff respectfully requests the court to grant him:


   1) An injunction to stop execution of judgement.


   2) An order for the return of money garnished from his corporation.


   3) Lift the restraining order allowing Plaintiff access to his Fair
      Grove Property.


   4) Grant other relief as the court sees fit.