Be careful with this. To have standing to file an action for wrongful foreclosure, you have to be the borrower or someone with a legal interest in the subject property. I assume you are proceeding as administrator of the estate, in which case you could (and should) bring these matters to the attention of the probate judge, who has the power to stop foreclosure and appoint an administrator on an emergency basis. As far as templates as concerned, if you google "california foreclosure preliminary injunction," you will find a number of them.
I agree with Mr. Graham's answer especially his note of caution. You need probate counsel. Documents you may find on the internet are generally ill suited for your purpose. If there are other heirs proceeding without counsel opens you up to personal liability for any mistake you may make. If you are a sole heir you stand to lose a lot if you get this wrong. Good luck.
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You need to see a probate attorney, right away. At the time of filing the petition to open probate, your attorney can also go in to court ex parte for temporary restraining orders to stop the foreclosure long enough to have a hearing on the facts, and from there probably get a preliminary injunction during the pendency of probate.
Richard A. Rodgers, Esq.
200 N. Westlake Blvd. Ste 201
Westlake Village, CA 91362
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