Sample Complaint to Stop Foreclosure Sale by Trustee in California

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This sample complaint to stop a foreclosure by a trustee in California includes a verified complaint for violations of the California Homeowner Bill of Rights, a violation of Civil Code section 2923.5 declaratory and injunctive relief, and accounting. The sample has been revised and updated as of March 18, 2018, is 34 pages and also includes an ex-parte application for a temporary restraining order to prevent the real property from being sold, an order to show cause for a preliminary injunction,  a sample declaration of ex-parte notice and a proposed order.  The sample includes a memorandum of points and authorities with citations to case law and statutory authority.

The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for sale. Note that the author is NOT an attorney and no guarantee or warranty is provided.