---
title: "Draft default or summary-judgment papers from the liquidated file"
url: "https://ailawframework.com/practice/debt-recovery-and-civil-enforcement/draft-default-or-summary-judgment-papers-from-the-liquidated-file"
type: "task"
site: "AI Law Framework"
id: "A46-A20260923-1"
practice_area: "Debt Recovery & Civil Enforcement"
tier: "yellow"
lawyer_review: "required"
last_reviewed: "2026-10-22"
---

# Draft default or summary-judgment papers from the liquidated file

> Under the lawyer's direction, work up the request for default judgment or the notice of motion for summary judgment, the interest-to-judgment and scale-costs calculation and the minute of judgment sought, from the…

Canonical page: https://ailawframework.com/practice/debt-recovery-and-civil-enforcement/draft-default-or-summary-judgment-papers-from-the-liquidated-file  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Debt Recovery & Civil Enforcement](https://ailawframework.com/practice/debt-recovery-and-civil-enforcement.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | Under the lawyer's direction, work up the request for default judgment or the notice of motion for summary judgment, the interest-to-judgment and scale-costs calculation and the minute of judgment sought, from the contract, the ledger, the demand and the court form the lawyer has named. The tool writes no part of any affidavit in the pack — not the affidavit of debt, not the affidavit of service, and not the affidavit verifying the facts and the belief that the defendant has no defence — no draft, no scaffold, no suggested paragraphs; on those it only indexes the exhibits, lists ledger entries with no source document, and checks the lawyer's sworn draft against the ledger and the court's form. |
| What the lawyer must review | Check the judgment sum, the interest period and rate and the costs claimed against the ledger, the contract and the current scale, and confirm the default or summary-judgment ground is made out under the rules of the court the claim is in. The affidavit of debt and the affidavit of service are the lawyer's own drafting: check every figure, date and exhibit reference against the source documents, and satisfy yourself the deponent has the knowledge deposed to, before it is sworn and filed. |
| Written for / versions | 1 jurisdiction versions below |

## Checking plan

Every figure must reconcile. Remove facts the client has not instructed. Service evidence is a human check.

- What the AI does: Under the lawyer’s direction, work up the request for default judgment or the notice of motion, the interest-to-judgment and scale-costs calculation and the minute of judgment sought. The tool writes no part of any affidavit in the pack.
- What the lawyer does: Set the scope, verify the evidence, resolve exceptions and approve the final output for its intended use.
- Basis: Suggested checking approach based on the task guidance. Complete the assessment for the actual tool, information and jurisdiction.

## Checks the lawyer makes

1. Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
2. Verify every relied-on citation, figure and name against the source document.
3. The responsible lawyer approves the exact version before use.

## Sources

- [Harvey: How to Write a Demand Letter Using AI](https://www.harvey.ai/blog/ai-demand-letter) (checked 2026-09-23)

## Forms and precedents for this task

| Form or precedent | Kind | AI level | Summary |
| --- | --- | --- | --- |
| [Claim (Form 2), statement of claim (Form 16) and default judgment (Queensland courts): debt recovery guide](https://ailawframework.com/precedents/debt-recovery-and-civil-enforcement/form-qld-claim-statement-of-claim-default-judgment.md) | Form | Yellow | Link to Queensland Courts' guide to recovering money owed, with the court for each claim value, Forms 2 and 16, filing copies, service within one year, the Form 46 affidavit of service, the 28-day… |
| [Application for order in default of defence (Magistrates' Court Form 21A)](https://ailawframework.com/precedents/debt-recovery-and-civil-enforcement/form-vic-mcv-21a-default-judgement.md) | Form | Yellow | Link to Magistrates' Court Form 21A, the application for an order in default of defence when a served complaint has no defence. |
| [Complaint (Magistrates' Court of Victoria Form 5A): starting a debt claim and the 21-day notice of defence](https://ailawframework.com/precedents/debt-recovery-and-civil-enforcement/form-vic-magistrates-complaint-5a.md) | Form | Yellow | Link to the Magistrates' Court of Victoria Form 5A complaint, with a guide to the plaintiff's address for service, the notice to the defendant, the 21-day time to give notice of defence (Form 8A) or… |
| [Litigation hold for a collection file](https://ailawframework.com/precedents/debt-recovery-and-civil-enforcement/us-collection-litigation-hold.md) | Notice | Yellow | Internal hold for the ledger, the contract, call recordings and the assignment chain when a collection suit or a consumer-debt dispute is reasonably anticipated. |
| [Default judgment for a liquidated demand (Supreme Court of Western Australia Form 32): completion guide](https://ailawframework.com/precedents/debt-recovery-and-civil-enforcement/form-wa-sc-default-judgment.md) | Form | Yellow | Link to Supreme Court of Western Australia Form 32, default judgment in an action for a liquidated demand. The forms table lists Order 13 rule 2 and Order 42 rule 1, and two copies for filing. |

Signed-in accounts can read the full text of each one.

## Jurisdiction versions

| Jurisdiction | Level |
| --- | --- |
| [United States](https://ailawframework.com/practice/debt-recovery-and-civil-enforcement/draft-default-or-summary-judgment-papers-from-the-liquidated-file/united-states.md) | Red |

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*