Ariz. Rev. Stat. § 33-721 : PROPERTY — MORTGAGES — FORECLOSURE —721 - Foreclosure of mortgage by court action TEXT PDF Mortgages of real property and deeds of trust of a type not included in the definition of deed of trust provided in section 33-801, notwithstanding any other provision in the mortgage or deed, shall be foreclosed by action in a court. A.R.S. § 33-721