"There is very little case law on the limits placed on the discretion of state courts to grant temporary restraining orders or preliminary injunctions against a foreclosure action," says Keith M. Aurzada, a partner in the Bankruptcy and Financial Restructuring Practice Group at Powell Goldstein LLP (Dallas). "There are even some debtors who venue-shop, filing motions in several courts with the hope of getting the right decision and consolidating the case with that judge," says Aurzada. He notes lenders with exposure in these states must understand, and prepare for, this low threshold for injunctive relief. "This includes monitoring loans in these states that have the potential to default, and then making sure you're covered at the courthouse. If a loan defaults, lenders should consider modifying their arguments for setting the bond amount, and ask for accrued interest and taxes as opposed to the full amount of the principle."