Defendant failed to file an Answer to Amended Complaint. The Amended Complaint included two additional claims. I will file the motion for default judgment or motion for judgment on the pleadings on those claims only. Which would it be, a motion for default judgment or a motion for judgment on pleadings? Do I need to include a brief in support of the motion? Do I need to cite law supporting the motion? This is a free gift so I don't want to screw it up? Anything in particular I need to be careful of or include in the motion? The attorney has no special circumstances to justify why he failed the answer, any reason why the judge would allow an answer 60 days late?