[COURT NAME]
[COUNTY], [STATE]

[PLAINTIFF NAME], )
Plaintiff, ) Case No. [CASE NUMBER]
v. )
[DEFENDANT NAME], )
Defendant. )

MOTION FOR DEFAULT JUDGMENT

NOTICE OF MOTION AND MOTION

PLEASE TAKE NOTICE that on [HEARING DATE] at [TIME], or as soon thereafter as counsel may be heard, [PLAINTIFF] will and hereby does move the Court for entry of default judgment against [DEFENDANT].

MEMORANDUM OF POINTS AND AUTHORITIES

I. Introduction

Default judgment is appropriate because [DEFENDANT] was properly served, failed to respond, and default has been entered.

II. Background

• Service of process: [DATE], [METHOD], proof filed on [DATE]
• Response deadline: [DATE]
• Default entered by [CLERK/COURT] on [DATE]

III. Legal Standard

A default judgment may be entered where a defendant fails to plead or otherwise defend after proper service. The Court must ensure jurisdiction, proper service, and a sufficient basis for liability and damages.

IV. Argument

A. The Court has jurisdiction and service was proper.
[Summarize jurisdictional basis and service details.]

B. The Complaint states valid claims for relief.
[Identify causes of action and how allegations establish liability.]

C. Damages are supported by competent evidence.
[Provide damages calculation and attach declarations, invoices, or expert support.]

D. Costs and fees are authorized.
[Identify statutory or contractual basis for costs, attorney fees, and interest.]

V. Requested Relief

[PLAINTIFF] respectfully requests that the Court:
1. Enter default judgment in the amount of $[AMOUNT].
2. Award pre-judgment interest of $[AMOUNT], as allowed by law.
3. Award attorney fees of $[AMOUNT] and costs of $[AMOUNT].
4. Grant any other relief the Court deems just.

CONCLUSION

For the foregoing reasons, the Court should enter default judgment.

Respectfully submitted,

text
Dated: [DATE]

______________________________
[ATTORNEY NAME]
[LAW FIRM]
[ADDRESS]
[PHONE]
[EMAIL]
Attorney for [PLAINTIFF]

CERTIFICATE OF SERVICE

I certify that on [DATE], I served the foregoing Motion for Default Judgment on [DEFENDANT/COUNSEL] via [METHOD OF SERVICE].

text
______________________________
[ATTORNEY NAME]

[PROPOSED] JUDGMENT

The Court, having considered [PLAINTIFF]'s Motion for Default Judgment, hereby enters judgment as follows:
1. Judgment is entered in favor of [PLAINTIFF] and against [DEFENDANT].
2. Damages: $[AMOUNT]
3. Pre-judgment interest: $[AMOUNT]
4. Attorney fees: $[AMOUNT]
5. Costs: $[AMOUNT]

IT IS SO ORDERED.

Dated: [DATE]

__________________________________
[JUDGE NAME]
[STATE] Judge