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Minimize the risk of using outdated forms and eliminate rejected fillings. Comment: This complaint seeks declaratory and injunctive relief concerning a scheduled foreclosure sale.Plaintiff's Name(s). This pleading is offered as a sample for educational purposes only. References to law and rules may not be current or accurate. Plaintiff filed a claim under G.S. 4521. 34 to enjoin the foreclosure sale of her home. Later, a new substitute trustee filed a second power of sale foreclosure. While scheduling and conducting foreclosure sales during the loan application process and during trial loan modification periods;. Case filed a "Verified Application to Enjoin Foreclosure.