While I am not aware of any orders for a copy of a deed only in a foreclosure matter, I do know that some of the LARGE title companies have been offering a title policy of coverage to the banks for coverage for a loan, using only a copy of the deed and a tax map number.  As we all know, just because there is not a judgment listed on the credit report does not mean it is not recorded in the Clerk's Office.  The lenders don't care.  They have been promised coverage.