What is a reasonable settlement rate to pay on a 13 year old secured debt?

I received a motion for default judgement from an old (13.5 years ago) credit card company. The original debt was $3900 (secured by personal belongings such as a vcr, camera, etc) and is now being sued for $16,700. I live in Ohio (think there is a 15 year statue of limitations), and cannot afford an attorney to help me. I contacted the plaintiffs attorney, and they are willing to accept payment arrangements or a settlement. I want to settle, but what amount should I offer? I did explain that if we cannot agree on a settlement, and the judgement is filed, I will have to file bankruptcy, but I prefer to prevent this. Is it common for a debt collection company (about the 3rd owner of this debt) to accept 30% of the original balance in 2-3 payments time? Please help with guidelines/suggestion