| name | foreclosure-complaint |
| title | Foreclosure Complaint |
| description | Drafts U.S. judicial foreclosure complaints pleading standing, chain of title, default, and amounts due with jurisdiction-specific compliance and exhibit control. Triggered when the user needs a foreclosure complaint, mortgage foreclosure pleading, note-and-mortgage enforcement action, or default-based real estate litigation involving acceleration, standing, or lost-note issues. |
| author | CaseMark |
| author_url | https://github.com/CaseMark/skills/tree/main/skills/legal/foreclosure-complaint |
| license | Apache-2.0 |
| version | 0.1.0 |
| execution_mode | open |
| jurisdiction | us |
| practice | real-estate |
| language | en |
| tags | ["drafting","litigation","pleading"] |
Foreclosure Complaint
Draft a court-ready judicial foreclosure complaint with verified standing, default allegations, and itemized relief.
Prerequisites
Collect before drafting:
- Loan documents — note, mortgage/deed of trust, riders, endorsements/allonges
- Assignment chain — each note/mortgage transfer with dates and recording data
- Payment history — last paid installment, default date, arrearage breakdown
- Pre-suit notices — breach/acceleration/right-to-cure letters with proof of service
- Property data — legal description, parcel ID, address, recording info
- Jurisdiction rules — venue statute, foreclosure statute, verification/affidavit requirements
- Interested parties — borrower(s), guarantors, junior lienholders, HOA/condo, tenants
Inputs
| Field | Required | Notes |
|---|
| Court/County | Yes | Must match property location and venue statute |
| Plaintiff identity | Yes | Entity type, state of formation, capacity (holder/servicer) |
| Defendant list | Yes | All parties with record or claimed interests |
| Note terms | Yes | Date, principal, rate, payment schedule, maturity |
| Mortgage terms | Yes | Date, recording book/page or instrument no. |
| Property legal description | Yes | Exact as recorded; include street address |
| Default date | Yes | First missed payment date |
| Amounts due | Yes | Principal, interest, fees, advances, per diem |
| Notices | Yes | Dates, method, content compliance |
| Standing facts | Yes | Chain of assignments and note possession |
| Modifications | If any | Dates, material terms, recalculated amounts |
Workflow
1. Build Pleading Structure
Follow this section order:
