This practice note discusses the relevant statutes, court rules, case law, and best practices for the commercial. To begin a foreclosure action, the noteholder's representative files various documents with the court in the form of a "complaint.Lis pendens is a notice lenders use when they initiate a foreclosure sale. The Answer is your response to the Summons and Complaint and tells the court your defenses or reasons why the mortgage Lender must not win the case. Get free access to the complete judgment in LUCAS v. FRAUDULENT CONVEYANCES — Bulk Sales Law — Nature and Form of Transfer — Chattel Mortgage. And document service fees, that are customarily incurred in a foreclosure action; and. 12-5. 070 No lien unless unpaid consideration stated. .