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Motion for Default Judgment

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MOTION FOR JUDGMENT
BY STIPULATION

JD-HM-13 Rev. 7-14

STATE OF CONNECTICUT
SUPERIOR COURT

www.jud.ct.gov

ADA NOTICE

The Judicial Branch of the State of Connecticut complies with the Americans with Disabilities Act (ADA). If you need a reasonable accommodation in accordance with the ADA, contact a court clerk or an ADA contact person listed at www.jud.ct.gov/ADA.

Motion

The parties move for judgment in accordance with the following stipulation.

Stipulation

By agreement of the parties, judgment for possession will enter in favor of the plaintiff with a stay of execution

below is to be filled in by the parties):

Order

The above motion for judgment is granted in accordance with the stipulation above.

FOR COURT USE ONLY

Distribution: Original - Court File Copy 1 - Plaintiff Copy 2 - Defendant

MOTION FOR JUDGMENT
BY STIPULATION

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What a Motion for Default Judgment Is and when it applies

A Motion for Default Judgment is a court filing asking the judge to enter judgment against a defendant who failed to plead or otherwise defend within the time required. It follows an entry of default and typically includes a factual showing of proper service, a statement of uncontested facts, and calculation of damages or relief requested. Federal courts follow Federal Rule of Civil Procedure 55 for entry of default and default judgment; many state courts use comparable local rules and procedures, so review the applicable rules before filing.

Why you would file a Motion for Default Judgment

A Motion for Default Judgment enables a plaintiff to obtain relief without a contested trial when the defendant fails to answer or appear. It preserves the plaintiff's right to enforce remedies and speeds resolution when liability is uncontested.

Why you would file a Motion for Default Judgment

Who typically prepares and files this motion

Plaintiffs and their counsel prepare motions for default judgment when an opposing party does not respond to a complaint within the required timeframe.

  • Plaintiff attorneys representing commercial creditors or contract claimants.
  • Small business owners or in-house counsel pursuing unpaid debts or breach claims.
  • Self-represented litigants in simpler civil matters seeking an uncontested judgment.

Core parts of a professional Motion for Default Judgment

A well-structured motion organizes evidence, statutory or rule citations, and a clear request for relief so the judge can enter judgment without unnecessary follow-up or hearing.

Case Caption

Full court name, docket number, and complete party names consistent with the original complaint and court filing records for proper identification.

Statement of Default

Concise factual statement showing the defendant was served correctly and failed to plead or appear within the period required by rule or statute.

Affidavit of Service

Sworn declaration verifying how, when, and where the defendant was served; must match the court's service requirements to prove jurisdiction.

Damages Calculation

Detailed, itemized computation of monetary relief claimed, including interest, fees, and a clear methodology for the court to adopt.

Proposed Judgment

A draft order or judgment the court can sign that mirrors the relief requested and includes precise language for enforcement.

Certificate of Service

Statement that the motion and supporting papers were served to the opposing party or their counsel, with method and date of service.

Required case and filing details to include

Case caption: Court and parties
Docket number: File number
Service date: Date served
Method of service: How served
Damages total: Amount claimed
Proposed order: Draft judgment

Step-by-step: preparing and filing the motion

Follow a clear sequence: confirm default, compile proof, draft the motion, and submit according to court rules.

  • 01
    Confirm default: Verify defendant failed to answer within the permitted time.
  • 02
    Gather proof: Assemble affidavits, service proof, and supporting exhibits.
  • 03
    Draft motion: Prepare concise legal argument and proposed judgment.
  • 04
    File and serve: E-file or deliver to clerk and serve opposing parties.

Configuring an online workflow for this motion

Set up template fields, signer authentication, and required attachments before sending to ensure a complete filing package.

Setting Recommended value
Template fields Prepopulate caption, case number, and dates
Conditional fields Show damage detail only when monetary relief requested
Authentication Use email or SMS code for affidavits
Attachments Attach service affidavit and exhibits as PDF

Where to file and how the routing works

Understand destination options: e-file to court clerk, submit by mail, or hand-deliver; serve opposing counsel per local rules.

  • Court e-file: Upload motion through court's e-filing portal
  • Clerk's office: Deliver printed copy if e-filing unavailable
  • Service on opponent: Serve by mail, email, or process server as allowed
  • Certificate of service: File to confirm opposing party received documents

Digital signing and e-submission considerations

Choose a platform that supports PDF attachments, clear audit trails, and the authentication level your jurisdiction requires.

  • Document formats: PDF and DOCX supported
  • Authentication options: Email, SMS, KBA
  • Integrations: Court e-file portals

Time-sensitive rules and common deadlines

Deadlines vary by jurisdiction; the Federal Rules of Civil Procedure (Rule 55) govern defaults in federal cases, while states use local rules with specific time limits.

Answer period:

Typically 21–30 days after service depending on rule

Default entry:

Clerk may enter default following proof of service

Motion timing:

File motion after default entry per local rules

Hearing notice:

Courts may set hearing dates for damages assessment

Enforcement:

Post-judgment collection timelines vary by statute

Key milestones from complaint to judgment

Track milestones closely to avoid procedural forfeiture and ensure the court has all proofs required to enter judgment.

01

Complaint filed

Initiates the case and starts service deadlines

02

Defendant served

Service date triggers the time to answer

03

Default entered

Clerk or court records defendant's failure to respond

04

Judgment requested

Plaintiff files motion and proposed order for court entry

Consequences of procedural or factual errors

Motion denial: Lacks required proof
Sanctions risk: Improper filings may trigger sanctions
Set-aside motion: Defendant may move to vacate default
Enforcement delays: Errors delay collection
Appeal vulnerability: Insufficient proof raises reversal risk
Interest miscalculation: Wrong amounts harm enforceability

Common preparation mistakes to avoid

  • Failing to attach a sworn affidavit of service or using an incorrect service date, which often results in the clerk refusing to enter default.
  • Submitting a vague damages statement without calculations or supporting invoices, leaving the court unable to determine the appropriate monetary award.
  • Using mismatched party names, docket numbers, or court captions that do not exactly match the original complaint, causing clerical rejection.
  • Neglecting to serve the motion and certificate of service on the opposing party as required, which can lead to denial or rehearing requests.

Supporting documents and export options

Include the affidavits, exhibits, proposed order, and certificate of service; export and archive in court-acceptable formats for filing and retention.

Supporting exhibits

Attach invoices, contracts, and payment records as PDF exhibits for the court's review.

Affidavit of service

File a notarized or sworn affidavit showing how and when service occurred.

Proposed order

Provide a clean, sign-ready proposed judgment the court can adopt without revision.

Export formats

Save final package as PDF/A and retain original DOCX versions for edits.

Illustrative case examples

Two concise examples show how motions for default judgment are used in practice and what a typical outcome looks like.

Commercial debt collection

A vendor filed suit for unpaid invoices and served the defendant using a process server.

  • The defendant did not respond within the answer period.
  • The court entered default judgment after the vendor submitted invoices, an affidavit of service, and a clear damages calculation, enabling collection efforts.

Uncontested contract breach

A small business sued for breach of a services contract and documented missed payments.

  • The defendant failed to appear or respond.
  • The court granted default judgment on the submitted motion and awarded the precise contract damages plus post-judgment interest.

eSignature vendor comparison for filing and service workflows

Platform pricing and capabilities vary; signNow is listed first for reference. Confirm each vendor's plan details and compliance features before purchase.

signNow DocuSign Adobe Sign PandaDoc HelloSign
Starting Price $8/user/mo $15/user/mo $14/user/mo $19/user/mo $15/user/mo
Free Trial 7-day free trial Varies by vendor Varies by vendor Varies by vendor Varies by vendor
Bulk Send Yes (Business Premium) Yes Yes Yes No
Audit Trail Yes Yes Yes Yes Yes
HIPAA Compliant Yes (BAA) Yes Yes No No

Frequently asked questions about Motions for Default Judgment

Answers to common procedural and evidentiary questions help avoid delays and support a complete and admissible filing.


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