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The judicial foreclosure process starts when a lender sues a delinquent borrower in the county where the property is located. To initiate the suit, the lender (the plaintiff) files a document called a “complaint for foreclosure” or “petition for foreclosure” in court. Plaintiff’s complaint for breach of contract, failure to provide notice pursuant to the security deed and failure to act in good faith and fair dealing regarding plaintiff’s loan modification and terms of the security deed, violation of Georgia Fair Lending Act, wrongful foreclosure, negligence, emotional distress, punitive damages, attorney’s fees and expenses.