7.06.150 Verified Complaint

The verified complaint in a mortgage foreclosure proceeding shall contain the following:

(a) The name of the borrower/mortgagor and each person or entity claiming through the borrower/mortgagor subsequent to the recording of the mortgage, including each subordinate lien holder as a defendant;

(b) A description of the property subject to the mortgage;

(c) A concise statement of the facts concerning the execution of the mortgage; the facts concerning the alleged default(s) of the borrower/mortgagor; and such other facts as may be necessary to constitute a cause of action;

(d) True and correct copies of the land assignment, the mortgage, or assignment thereof relating to the property (appended as exhibits); and

(e) Any applicable allegations concerning relevant requirements and conditions prescribed in:

(1) federal statutes and regulations;

(2) Tribal codes, ordinances and regulations; and/or

(3) provisions of the land assignment.