Fill and Sign the Alabama Complaint to Enjoin a Foreclosure Form

IN THE CIRCUIT COURT OF ________________________ COUNTY, ALABAMA (MORTGAGOR), * Plaintiff, * vs. * CIVAL ACTION NO. (MORTGAGEE), * Defendant. * A COMPLAINT TO ENJOIN A FORECLOSURE COMES NOW PLAINTIFF and brings this complaint against Defendant and respectfully shows unto t he Court as follows: 1. Plaintiff is a citizen of the State of Alabama and is at least 19 years of age. 2. Defendant is a corporation doing business in the State of Alabama having its principal place of business at ______________________. 3. Plaintiff executed a mortgage and promissory note on ______________, _________, to Defendant, __________________. The indebtedness was secured to real property found in _____________________ County, Alabama to wit: (DESCRIBE PROPERTY) __________________ __________________________________________ ________________________________________________________________________ ________________________________________________________________________ ____________________________________________________________________ ____ 4. Attached hereto is a copy of aforesaid mortgage and promissory note and marked as Exhibit 1 and 2, respectively. Aforesaid exhibits are incorporated into this Complaint. 5. Plaintiff avers that on ___________________, _____________, Defendant pu blished notice of foreclosure in the ___________________, a newspaper insert found in the ________________________. 6. Plaintiff further avers that the ________________ is not a newspaper of general circulation in ___________________ County as required by the Code pre - foreclosure requirements. WHEREFORE, Plaintiff prays that this Honorable Court Order a Temporary Restraint and Injunction on said foreclosure sale because Defendant has failed to follow statutory requirements of a power of sale foreclosure. P laintiff further prays for such other relief, including reasonable attorney's fees, as this Honorable Court deems appropriate and proper. Attorney for Plaintiff ________________________