Check "General Denial". Title Insurance real estate forms archive containing over 300 forms in MS Word and Adobe acrobat format.In Wells Fargo Bank, N.A. v. New York is a judicial foreclosure state, which means that the lender has to sue the borrower in order to enforce their rights under the mortgage and note. These Foreclosure Forms are for All Courts that preside over Residential Foreclosure Cases. A plaintiff must allege that it is in possession of the underlying Note in order to establish that it has standing to prosecute the action. Therefore, courts in other states may take a variety of approaches in analyzing the effect of an assigned lost note. In such cases, borrowers must execute new documents, which starts with completing a lost note affidavit. To bring a foreclosure action in NY, plaintiff must own both the mortgage and note at the inception of the action; Deutsche Bank National Trust Company v. Lost Certificated Interest in a Real Estate Mezzanine Transaction.