Avramidis v. Arco Petroleum Company, 623 F. Supp. 64 (D. Mass. 11-27-85); rev'd C.A. No. 85-3972-G (D. Mass. 2-11-86), Slip Opinion; aff'd, 798 F.2d 12 (1st Cir. 8-12-86); 120 F.R.D. 450 (D. Mass. 6-15-88)

The court found that it had discretion to order franchisees to post a bond prior to issuing a preliminary injunction, but franchisors did not make an adequate showing to require it.