Read Microsoft Word - SFC_Motion for Preliminary Injunction Massachusetts.doc text version

COMMONWEALTH OF MASSACHUSETTS _________________ [county], SS. SUPERIOR COURT C.A. No.: __________________________, Plaintiff ) ) ) v. ) ) _________________________ ) Defendant[s] ) ____________________________________)


PLAINTIFF, ___________________'S MOTION FOR PRELIMINARY INJUNCTION TO STOP FORECLOSURE SALE Now comes the Plaintiff, ____________________, and hereby moves that this Honorable Court enter an Order preliminarily enjoining the Defendant from taking any actions and/or proceedings toward and/or relating to the foreclosure of the property situated at ____________________________ (the "Property"). The Property presently

serves as the residence of Plaintiff, and its loss would result in catastrophic injury to Plaintiff and Plaintiff's dependents. As reasons therefore, Plaintiff states: BACKGROUND 1. Plaintiff obtained a loan on the Property, which functions as his/her

personal residence, on or about ________ [insert date] for $ _____________ from Defendant(s). The loan is memorialized via a Deed of Trust and, Promissory Note, wherein the lender was identified as "______________"

original loan documents]. [insert name of lender identified in the


In procuring the subject loan, the Defendants willfully and cynically

exploited the Plaintiff's lack of experience and understanding in financial matters.



Microsoft Word - SFC_Motion for Preliminary Injunction Massachusetts.doc

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