Isisis gives good advise.
Also
Technically it is against CFPB (Consumer Financial Protection Bureau) rules against "dual tracking." Lender can't simultaneously move to foreclose and move to modify. Please google that for the specific regulation cause I don't have it ready at hand. Include the rule or regulation as a reason for your request. If you have a letter saying such, that is even better and you should include it. You would want an injunction to stop the sale during pending modification process and under review. I don't know if you can necessarily stop them from scheduling a sale date. Also include that a sale would cause irreprable harm as you intend to modify and resolve loan outside of court, This does not need to be lengthy motion.
I don't know if you have an attorney or not. I always recommend going to the local legal aid organization in your State. Right now preventing foreclosures and evictions is a priority for these legal service organizations. In general, you will have to qualify by income or by need. Some have self-help resources too.
Otherwise, as a pro se defendant, you need to learn local court rules and motion practice. Typically filing a motion includes filing a proposed order for the Judge to sign. IE I usually restate the action (injunction to stop sale during negotaions) and include an area for the Judge to check a yes/no agreement on simple orders.
Most of this is State specific. I am not an attorney.
Good luck!
Selene finace the loan servicer has told us the loan is under review and the forclosure is on hold, same day the plaintiffs attorney made a motion to open judgment and set a new sale date. Can I make a motion to object a to this motion. Open for all suggestions.
Thank you