[STATE] [COURT NAME]

[COUNTY] COUNTY

[PLAINTIFF NAME],
Plaintiff,

v.

[DEFENDANT NAME],
Defendant.

Case No.: [CASE NUMBER]
Judge: [JUDGE NAME]
Department/Division: [DEPARTMENT]

STIPULATION FOR ENTRY OF JUDGMENT AND ORDER

(Consent Judgment in Debt Collection Matter)

PARTIES' STIPULATION

The undersigned parties, Plaintiff [PLAINTIFF NAME] ("Plaintiff" or "Creditor") and Defendant [DEFENDANT NAME] ("Defendant" or "Debtor"), hereby stipulate and agree as follows:

1. PROCEDURAL BACKGROUND

1.1 Commencement of Action

Plaintiff commenced this action on [DATE] by filing a Complaint seeking to recover:

☐ Principal debt in the amount of $[PRINCIPAL]
☐ Pre-judgment interest of $[INTEREST]
☐ Attorney fees and costs
☐ Other relief: [DESCRIBE]

1.2 Nature of Underlying Debt

The debt that is the subject of this action arose from:

☐ Credit card account with [ORIGINAL CREDITOR]
☐ Personal loan with [ORIGINAL CREDITOR]
☐ Medical debt owed to [ORIGINAL CREDITOR]
☐ Commercial transaction with [ORIGINAL CREDITOR]
☐ Deficiency following repossession/foreclosure
☐ Other: [DESCRIBE]

Account Number: [ACCOUNT NUMBER]
Date of Original Obligation: [DATE]
Date of Default: [DATE]

1.3 Current Procedural Status

☐ Default has been entered against Defendant
☐ Defendant has filed an Answer
☐ Discovery is ongoing/completed
☐ Trial is set for [DATE]
☐ Other: [DESCRIBE]

2. STIPULATED FACTS

The parties stipulate to the following facts for purposes of this Stipulated Judgment only:

2.1 Defendant acknowledges:

☐ The debt described in the Complaint is valid and owing
☐ The amount claimed by Plaintiff is accurate
☐ Defendant has no valid defenses to the debt
☐ Plaintiff is the proper party to collect the debt

2.2 Alternatively (Non-Admission):

☐ Without admitting liability, Defendant agrees to entry of this Stipulated Judgment to resolve the dispute

3. JUDGMENT AMOUNT

3.1 Total Judgment

The parties stipulate to entry of judgment in favor of Plaintiff and against Defendant in the following amounts:

3.2 Post-Judgment Interest

The judgment shall bear post-judgment interest at the rate of:

☐ [RATE]% per annum (statutory rate)
☐ [RATE]% per annum (contractual rate, if enforceable)
☐ As provided by [STATE] law

4. PAYMENT TERMS

4.1 Payment Schedule

☐ Option A: Lump Sum
Defendant shall pay the full judgment amount of $[AMOUNT] within [NUMBER] days of entry of this Stipulated Judgment.

☐ Option B: Installment Payments
Defendant shall pay the judgment amount according to the following schedule:

Monthly Payment Amount: $[MONTHLY PAYMENT]
Number of Payments: [NUMBER]
First Payment Due: [DATE]
Day of Month Due: [DAY] of each month

4.2 Payment Method

Payments shall be made to:

Payee: [PLAINTIFF/ATTORNEY NAME]
Address: [PAYMENT ADDRESS]
Reference: Case No. [CASE NUMBER]

☐ Automatic Payment Authorization: Defendant authorizes automatic withdrawal from:
Bank: [BANK NAME]
Routing: [ROUTING NUMBER]
Account: XXXX[LAST 4]

4.3 Application of Payments

Payments shall be applied first to post-judgment interest, then to costs and fees, and finally to principal.

5. STAY OF EXECUTION

5.1 Conditional Stay

So long as Defendant remains current on all payments as set forth in Section 4, Plaintiff agrees to:

☐ Stay execution on the judgment
☐ Not record the judgment as a lien on real property
☐ Not pursue wage garnishment
☐ Not pursue bank levy
☐ Not report the judgment to credit bureaus

5.2 Termination of Stay

The stay of execution shall terminate immediately upon:

☐ Defendant's failure to make any payment within [NUMBER] days of its due date
☐ Defendant's failure to maintain current contact information with Plaintiff
☐ Defendant's filing for bankruptcy protection
☐ Any other material breach of this Stipulation

5.3 Notice of Default

Before pursuing execution, Plaintiff shall provide Defendant with written notice of default and [NUMBER] days to cure.

6. DEFAULT PROVISIONS

6.1 Consequence of Default

If Defendant defaults on any payment obligation and fails to cure within the notice period:

☐ The entire remaining balance shall become immediately due and payable
☐ Plaintiff may execute on the judgment without further notice
☐ Any stayed interest shall be reinstated and added to the balance
☐ Plaintiff may recover additional attorney fees and costs incurred in enforcement

6.2 Enforcement Remedies

Upon default, Plaintiff may pursue all available legal remedies, including but not limited to:

☐ Wage garnishment (subject to applicable exemptions)
☐ Bank account levy
☐ Recording judgment as lien on real property
☐ Writ of execution against personal property
☐ Debtor's examination/judgment debtor examination
☐ Other lawful remedies

7. SATISFACTION OF JUDGMENT

7.1 Acknowledgment of Satisfaction

Upon receipt of all payments under this Stipulation, Plaintiff agrees to:

☐ File an Acknowledgment of Satisfaction of Judgment with the Court within [NUMBER] days
☐ Provide Defendant with a copy of the filed Acknowledgment
☐ Release any liens recorded pursuant to the judgment

7.2 Partial Satisfaction

Plaintiff agrees to file partial satisfactions upon Defendant's written request reflecting payments made.

8. REPRESENTATIONS AND WARRANTIES

8.1 Defendant Represents and Warrants:

☐ Defendant has read and understands this Stipulation
☐ Defendant has had the opportunity to consult with an attorney
☐ Defendant is entering into this Stipulation voluntarily
☐ Defendant has the ability to make the payments as scheduled
☐ Defendant is not currently in bankruptcy and has no intention of filing

8.2 Plaintiff Represents and Warrants:

☐ Plaintiff is the lawful owner of the debt or is authorized to collect on behalf of the owner
☐ Plaintiff has authority to enter into this Stipulation
☐ The judgment amount is accurate
☐ Plaintiff will comply with all terms of this Stipulation

9. RELEASE OF CLAIMS

9.1 Mutual Release

Upon full satisfaction of the judgment, the parties mutually release each other from any and all claims arising from the debt that is the subject of this action.

9.2 Preservation of Enforcement Rights

Nothing in this Stipulation shall limit Plaintiff's right to enforce the judgment if Defendant defaults.

10. MISCELLANEOUS PROVISIONS

10.1 Entire Agreement

This Stipulation constitutes the entire agreement between the parties regarding resolution of this action.

10.2 Modification

This Stipulation may only be modified by written agreement signed by both parties or by order of the Court.

10.3 Governing Law

This Stipulation shall be governed by the laws of the State of [STATE].

10.4 Jurisdiction

The Court shall retain jurisdiction to enforce this Stipulation and the judgment entered pursuant hereto.

10.5 Notices

All notices shall be sent to the addresses set forth below or as subsequently provided in writing.

10.6 Waiver

The failure of either party to enforce any provision shall not constitute a waiver of that provision.

10.7 Severability

If any provision is held invalid, the remaining provisions shall remain in full force and effect.

11. SIGNATURES

11.1 Plaintiff

PLAINTIFF [OR PLAINTIFF'S COUNSEL]:

Signature: ___________________________________ Date: _______________

Print Name: ___________________________________

☐ Attorney for Plaintiff
Bar Number: ___________________________________
Firm: ___________________________________
Address: ___________________________________
Phone: ___________________________________
Email: ___________________________________

11.2 Defendant

DEFENDANT:

Signature: ___________________________________ Date: _______________

Print Name: [DEFENDANT NAME]

Address: ___________________________________

Phone: ___________________________________

Email: ___________________________________

OR

DEFENDANT'S COUNSEL:

Signature: ___________________________________ Date: _______________

Print Name: ___________________________________

Bar Number: ___________________________________

Firm: ___________________________________

Address: ___________________________________

ORDER

THE COURT, having reviewed the foregoing Stipulation and finding good cause therefor, hereby ORDERS:

1. The Stipulation for Entry of Judgment is APPROVED and incorporated herein by reference.

2. Judgment is entered in favor of Plaintiff [PLAINTIFF NAME] and against Defendant [DEFENDANT NAME] in the total amount of $[TOTAL JUDGMENT], plus post-judgment interest at the rate of [RATE]% per annum.

3. Execution on this judgment is STAYED so long as Defendant complies with the payment terms set forth in the Stipulation.

4. Upon default by Defendant as defined in the Stipulation, Plaintiff may apply ex parte for issuance of a writ of execution.

5. The Court retains jurisdiction to enforce this Stipulation and Judgment.

IT IS SO ORDERED.

Date: _______________

_________________________________________
HONORABLE [JUDGE NAME]
Judge of the [COURT NAME]

NOTICE TO DEFENDANT

IMPORTANT: By signing this Stipulation, you are agreeing to have a judgment entered against you. A judgment:

☐ Becomes a public record
☐ May appear on your credit report for up to 7 years
☐ May affect your ability to obtain credit, housing, or employment
☐ Creates a lien on any real property you own in this county
☐ May be enforced through wage garnishment, bank levy, or seizure of property if you default

You have the right to consult with an attorney before signing this document.