California, United States of America
The following excerpt is from Ung v. Headman, H042617 (Cal. App. 2017):
Thus, the two-year limitations period set forth under section 473.5 applies, and section 473, subdivision (d) cannot offer appellant any relief. A motion to vacate a default and a default judgment under section 473 is reviewed for an abuse of discretion. (Parage v. Couedel (1997) 60 Cal.App.4th 1037, 1041.) Since appellant's motion under section 473 was untimely, the trial court did not abuse its discretion in denying it on this ground.
2. Equitable Relief on the Ground of Extrinsic Fraud or Mistake
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