The plaintiff must serve the defendant with the foreclosure complaint. This can be done through certified mail, a courier service or in person.We can provide you with samples of court forms that are available. • We can provide you with guidance on how to fill out forms. Learn about the difference between a complaint, summons, and lis pendens in a judicial foreclosure. Before a residential mortgage can be foreclosed in Pennsylvania, the lender must give a 30-day notice of intention to foreclose (also known as an Act 6 Notice). You can file complaint; however it will likely be dismissed shortly if the other side presents the judgement in the case you are currently appealing. What Is An Affirmative Defense? Nonpayment proceedings very frequently end in the payment of money rather than eviction. Marin works primarily in the Secured.