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negotating paying a old judgment exchange for them to vacate

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The better tact is to bring the motion yourself and have them agree they won't oppose it. That is, if you can still bring it. In NYS, for example, you have but 1 year to try to open a default judgment.

You will need to prepare a stipulation of discontinuance and a release to go with your motion, since the vacation makes it a "live" action.

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