California, United States of America
The following excerpt is from Ostling v. Loring, 27 Cal.App.4th 1731, 33 Cal.Rptr.2d 391 (Cal. App. 1994):
3 An order denying a motion to set aside a default is not appealable; however, it may be reviewed on appeal from the default judgment. (See, e.g., Lopez v. Fancelli, supra, 221 Cal.App.3d at p. 1307, fn. 2, 271 Cal.Rptr. 87.) No appeal was taken from the default judgment in this case.
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