STATE OF MINNESOTA		
COUNTY OF HENNEPIN

__________________________			           Plaintiff(s),

vs.	

___________________________
		           Defendant(s)

DISTRICT COURT
FOURTH JUDICIAL DISTRICT
Case Type: Other Civil

Case No.  _______________

                   COMPLAINT
                    Minn. Stat. §582.032

Plaintiff for its Complaint against Defendant(s) states and alleges as follows:

1.	Plaintiff is a ____________ organized under the laws of ___________.
2.	Defendant(s), ______________________________ is/are the owner(s) of real property in Hennepin County, Minnesota legally described as follows:

and having an address as follows:

3.	On ___________, _______ Defendants, ___________, executed and delivered to _________________ a note in the principal amount of $___________ (the “Note”).
4.	To secure payment of the Note, ______________ executed and delivered a mortgage in favor of _______________, dated _________ and filed on _____________ as Hennepin County (Recorder/Registrar of Titles) Document No. _________ (the “Mortgage”), which mortgaged the premises described in paragraph 2, above.
5.	Plaintiff is now the owner of the Mortgage [pursuant to an Assignment of Mortgage dated __________ and filed on ____________ as Hennepin County (Recorder/Registrar of Titles) Document No.  _____________].
6.	There has been a default in the payment of money under the Mortgage for at least 60 days as of the date of this Complaint.
7.	Plaintiff has commenced a foreclosure of the Mortgage by advertisement and the notice of sale contains the statement required by Minnesota Statutes, Section 580.04 (a)(7).
[or]
Plaintiff has completed a foreclosure of the Mortgage by advertisement, the notice of sale contains the statement required by Minnesota Statutes, Section 580.04 (a)(7), and the Sheriff’s Certificate of Sale was filed on ______________ as Hennepin County (Recorder/Registrar of Titles) Document No. ________________.  Plaintiff has included as Defendants the holders of junior liens and interests who requested notice of any post-foreclosure action to reduce the mortgagor’s redemption period by filing a certificate in accordance with Minnesota Statutes, Section 582.032, Subd. 3, and those defendants are: __________________________(if none, state “none”.) 
8.	The mortgagor(s) (or assigns of record)  is/are not currently in the military service of the United States. 
9.	The mortgaged premises are:
a.	ten acres or less in size;
b.	improved with a residential dwelling consisting of less than five units, which is not a model home or a dwelling under construction;
c.	not property used in agricultural production;  and 
d.	abandoned.
10.	The mortgaged premises are vacant, unoccupied and abandoned as required by Minnesota Statutes, Section 582.032, Subd. 7.

WHEREFORE, Plaintiff requests an Order as follows:

1.	The mortgagor’s redemption period under the foreclosure of Mortgage Document No. __________ is reduced to five weeks.

2.	For such other and further relief as the Court deems just and proper.

Date: ___________________	

[Name of law firm]

By:  _____________________________
[Name, address, email address, telephone number, and license number of attorney for Plaintiff]
Acknowledgment
The undersigned attorney for Plaintiff acknowledges that sanctions may be imposed in this action under Minnesota Statutes, Section 549.211 for violation of the provisions of the section.

Date: ___________________	

By: _______________________