Curing Default Judgments

I am not a lawyer. This is my opinion and ajudgment is to ask the court to vacate (cancel)
summary of what I have learned and observed.the judgment.
If you need legal advice, contact a lawyer.If they succeed on a motion to vacate, you lose
To start a lawsuit, legal papers (called thethe judgment, and have to start over with a new
complaint) must first be served on the defendant.trial. The most important issue a judge considers
The defendant becomes a debtor when a judgeon a motion to vacate, is the proof of service.
signs an order creating a civil judgment.The best proof of service is when a Sheriff or a
If the defendant does not provide an answerregistered process server personally serves the
within a certain period of time, and/or does notdefendant, or serves the correct person at a
show up on the date of the court hearing, thecompany. With valid personal service, attempts to
defendant becomes a debtor, and a defaulthave the court vacate the judgment almost
Judgment results.never succeed.
A default means you won your lawsuit. In manyNote the debtor can play other games, including
ways, this is good news - the judge ruled in yourfiling an answer (e.g.) one day after the deadline,
favor, there were no delays, no extra expenses,and later try to add that to their (alleged) reasons
and you didn't have to hear or read the debtor'sfor the court to grant a motion to vacate the
lies in court.judgment. Judges like to give defendants extra
However, a default judgment (where the debtorleeway, as they want all sides to have their day in
did not show up) is sometimes a hollow victory.court, even if they defaulted.
Many debtors do not care about defaultYou don't get to choose whether your lawsuit
judgments. This is because the common senseresults in a default judgment or not. You can
definition of a default, does not apply in civilchoose how carefully you serve the right
courts. Most of the time when you default, youdefendant, and make sure to use a registered
lose. In civil court, a default is often a secondprocess server or a sheriff, to personally serve
chance for a debtor to avoid paying a judgment.the defendant.
Other disadvantages of a default judgmentSometimes you can't personally serve the
include:defendant. In this case, you must have a
1) If the court notice of the default does notsubstitute service done on (e.g) their spouse, or
mention a dollar amount, you must get a judge toservice by publishing in a newspaper (how
sign an order to make it an enforceable moneyobsolete). When you have a default judgment
judgment.with less than perfect proof of personal service,
2) You can't do pre-judgment discovery on theit's considered a weak judgment.
debtor. This means you may have to later doOne way to "clean up" a weak judgment is to
post-judgment discovery to show fraudulentlater personally serve the debtor with a post
transfers or find the debtor's assets.judgment document such as an abstract of
3) Default judgments are harder to domesticatejudgment, or a memorandum of costs, or an
(transfer) into some other states. (E.G.,order of examination. Six months after a debtor
Connecticut, New Jersey, and New York).is personally served, they are considered
4) Debtors don't care about default judgments. Ifpersonally aware of the judgment, even if the
they cared, they would have either paid you, orfirst service on them was substituted service.
showed up in court to contest your complaint. IfWhen judgments have substitute service, it's
you or a judgment enforcer takes their assets,often a good idea to personally serve the debtor
they may suddenly care very much. The mostsomething, and wait 6 months before taking
popular way debtors try to avoid paying aaggressive enforcement actions.