Rule 69 Depositions

"Relentless Collection Attorneys"

Rule 69 of the Massachusetts Rule of Civil Procedure Rule allows a creditor to take post judgment discovery to aid in the collection of an execution. This allows the creditor to examine the defendant’s bank accounts and financial statements. These records can lead to the discovery of hidden assets which can either be seized or liquidated to be applied to your execution.

At the Law Offices of Alan M. Cohen LLC, we use post judgment depositions to follow the money. We use both document only depositions as well as live testimony depositions. Depositions can also require both live testimony and the production of documents at the same time.

Sometimes we depose the debtor directly. More often we depose those businesses and people who have knowledge about the judgment debtor’s assets. The depositions start with banks and work all the way through the judgment debtor’s accountants or business partners. Bank records can indicate where and on what your debtor spend its money. They can provide insight whether there is a basis to try to pierce the corporate veil to impose individual liability. Bank records can also disclose purchases which the judgment debtor made which may turn out to be a saleable asset.

Sometimes post judgment discovery will show payments to credit cards or rental payments. This information can lead to further post judgment discovery as we work tirelessly to jump over the hurdles that the debtor has either intentionally or inadvertently placed in your way to slow or prevent payment of judgment obligations.

The beauty of post judgment discovery is that the only limitation on the information you can seek concerning the debtor’s ability to pay your judgment is your attorney’s imagination. With over thirty-five years of successful experience in collecting judgment debt, we have a number of tactics which we use to get our clients paid.

We never give up as getting our clients paid is our top priority.

When your serious about getting paid on your outstanding judgment call the  AV rated experienced Boston trained business debt collection lawyer who collects bad debts throughout Massachusetts at  (508) 620-6900 or email

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