Section PRP.05.42 — Complaint

Upon fulfillment of the conditions to commencing a foreclosure, the Mortgagee may commence a foreclosure action by filing a verified complaint, which shall include:

(a) The name of the Mortgagor and each person or entity claiming an interest in the Leasehold Interest, including each Subordinate Lienholder (except for the Tribe with respect to a claim for a Tribal taxes), as a defendant;

(b) A description of the Leased Premises;

(c) A concise statement of the facts concerning the execution of the Mortgage and the Lease, if applicable; the facts concerning the recording of the Mortgage; the facts concerning the alleged default(s) of the Mortgagor; and such other facts as may be necessary to constitute a cause of action;

(d) True and correct copies of each Note, Mortgage, deed of trust or other recorded real property security instrument, Lease (if applicable) and any assignment of any of these documents; and

(e) Any applicable allegations concerning compliance with any relevant requirements and conditions prescribed in (i) federal statutes and regulations, (ii) Tribal codes, ordinances and regulations, and/or (iii) provisions of the Note, Mortgage and the Lease.