In the MUNICIPAL COURT of Philadelphia county

Attorney Name (ID #XXXXX)
Attorney Email 
Firm Name 
Address 1
Philadelphia, PA 19XXX
Attorney Phone Number 

:
Landlord Name 	:
Address 1	:
Address 2	:	
Plaintiff	:                            LT-1X-XX-XX-XXXX
:
:
v.	:
:
:
Tenant Name 	:
Address 1	:
Address 2	:
Defendant	:	
:

PETITION TO VACATE THE JUDGMENT AND DISMISS MATTER

1.	On DATE, a Judgment by Agreement was entered by plaintiff and defendant for possession of the property at ADDRESS  [and money judgment for $00,000]. SEE: Exhibit A: JBA.

2.	The terms of the judgment are as follows: “Defendant to vacate the premises on or before 02/01/2019 and leave premises in broom swept condition…..As long as above defendants vacate timely and returns the keys plaintiff will not oppose defendant’s petition to vacate the judgment.” 

3.	Defendant moved out on DATE and left the property in broom swept condition.   

4.	Defendant received a receipt from the property manager when she returned the keys. SEE: Exhibit B: Receipt.

5.	Defendant therefore fulfilled all of the terms of the Judgment by Agreement. 

6.	Plaintiff stipulates that the judgment should be marked satisfied and dismissed in line with the terms of the Judgment by Agreement. SEE: Proposed Order to Vacate. 

7.	Failure to have this Judgment vacated hurts defendant’s credit and makes it more difficult for defendant to find reasonable housing.

WHEREFORE, YOUR Petitioner respectfully requests the Court to vacate the Judgment dated
DATE.

Dated: DATE	Respectfully submitted,

__________________	
NAME
Attorney for Defendant