Tennessee Complaint for Judicial Foreclosure Sale — Merge Template

Tennessee Complaint for Judicial Foreclosure Sale — Merge Template

Tennessee is a non-judicial foreclosure state — but when a federal lien is involved, everything changes. When HUD, FHA, or another federal agency holds a subordinate interest on the property, the lender must proceed by judicial foreclosure under 28 U.S.C. § 2410(c) to extinguish that federal lien and deliver clean, marketable title.

This ready-to-use merge template is built from a real attorney-drafted filing in Tennessee Chancery Court. Every case-specific detail is a bold yellow-highlighted merge field — fill them in and it's ready to file.

What's Included:

• Complete Complaint for Judicial Foreclosure Sale — all four sections fully drafted: Parties, Jurisdiction & Venue, Facts, and Claim for Relief, plus the full WHEREFORE prayer
• Tennessee Chancery Court caption table — two-column format with court name, county, judicial district, city, docket number, and all party fields
• Fully merge-ready — bold highlighted fields for: County, Plaintiff Name, all Defendant names, Judicial District, Borrower name, Property Address, Legal Description, Note date and amount, Original Lender, Trustee Name, Deed of Trust recording date and instrument number, Date of Default, Outstanding Principal Balance, HUD Subordinate Amount, submission date, and full attorney signature block
• Built for federal lien scenarios — HUD subordinate deed of trust language, 28 U.S.C. § 2410(c) judicial sale authority, and HUD one-year right of redemption preservation language all included
• Flexible defendant structure — fields for multiple subordinate lienholders (junior deed of trust, UCC financing statement, judgment liens) — add or remove as needed
• Certificate of Service — includes service blocks for Borrower, US Attorney General, US Attorney (with district field), Secretary of HUD, and additional subordinate lienholders
• Exhibit list — Exhibits A through G with merge fields for custom descriptions
• Cites Tennessee statutes throughout — T.C.A. § 16-11-101, § 20-4-103, § 29-14-101, § 35-5-101
• BPR Number field included — Tennessee Board of Professional Responsibility number on both signature blocks

This template is sold for informational and drafting purposes only and does not constitute legal advice. Users are responsible for ensuring compliance with current Tennessee statutes and local court rules.