The following decision affects all mortgage foreclosure proceedings in the state of Delaware
whether proceeding on the mortgage, the note or both. Plaintiff’s counsel must now include a
statement in the pleading confirming that the Plaintiff is the current holder of the note at the
time the complaint is filed. This requires the Plaintiff to provide counsel with a copy of the
note and/or any allonge so that Plaintiff’s counsel can confirm the note is either endorsed to
the Plaintiff or endorsed enblank and that the Plaintiff is the holder of the note with the right
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