---
title: "Build the record for a federal default or summary-judgment motion"
url: "https://ailawframework.com/practice/debt-recovery-and-civil-enforcement/draft-default-or-summary-judgment-papers-from-the-liquidated-file/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A46-A20260923-1-US"
practice_area: "Debt Recovery & Civil Enforcement"
tier: "red"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Build the record for a federal default or summary-judgment motion

> From the file the lawyer marks, list each element, the document that shows it, and whether the amount is a sum certain that can be computed. Write no sentence of the motion and no statement for the clerk.

Canonical page: https://ailawframework.com/practice/debt-recovery-and-civil-enforcement/draft-default-or-summary-judgment-papers-from-the-liquidated-file/united-states  
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 | Red: Lawyer writes; AI may check, clarify or collect data |
| How AI is used | From the file the lawyer marks, list each element, the document that shows it, and whether the amount is a sum certain that can be computed. Write no sentence of the motion and no statement for the clerk. |
| What the lawyer must review | In federal court, Rule 55(a) requires the clerk to enter a default when a party has failed to plead or otherwise defend and that failure is shown. Rule 55(b)(1) lets the clerk enter judgment for a sum certain, on request, with a statement showing the amount due. You prepare that statement. In other cases you apply to the court under Rule 55(b)(2). A default judgment against a minor or incompetent person requires representation. Rule 56(a) requires the movant to show there is no genuine dispute as to any material fact and that the movant is entitled to judgment as a matter of law. Rule 11 is your certification of the paper. State courts use their own default rules. |
| Written for | United States |
| Applies to | [Draft default or summary-judgment papers from the liquidated file](https://ailawframework.com/practice/debt-recovery-and-civil-enforcement/draft-default-or-summary-judgment-papers-from-the-liquidated-file.md) |

## Checking plan

- What the AI does: From the file the lawyer marks, list each element, the document that shows it, and whether the amount is a sum certain that can be computed. Write no sentence of the motion and no statement for the clerk.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- The Rule 55 advisory note says the servicemembers' relief statute affects Rule 55(b). Open the current Act before judgment.
- Rule 55(d) limits default judgment against the United States, its officers and its agencies.

## Sources

- [Federal Rule of Civil Procedure 55](https://www.law.cornell.edu/rules/frcp/rule_55) (checked 2026-10-22)
- [Federal Rule of Civil Procedure 56](https://www.law.cornell.edu/rules/frcp/rule_56) (checked 2026-10-22)
- [Federal Rule of Civil Procedure 11](https://www.law.cornell.edu/rules/frcp/rule_11) (checked 2026-10-22)

## 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.

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