California, United States of America
The following excerpt is from Kramer v. Traditional Escrow, Inc., 270 Cal.Rptr.3d 101, 56 Cal.App.5th 13 (Cal. App. 2020):
Given defendants' inability to satisfy the satisfactory excuse or diligence prong, we do not address whether they have a meritorious defense. However, we note that in their meritorious defense argument, defendants suggest that the trial court should not have entered a default judgment against them because plaintiff did not support the amount of the judgment with admissible evidence. (See Cal. Rules of Court, rule 3.1800(a)(2).) Defendants do not appear to offer this argument as an independent ground for vacating the judgment outside the context of extrinsic fraud or extrinsic mistake. To the extent they do, we will not address the argument since, among other things, it is not stated under a separate heading. ( Cal. Rules of Court, rule 8.204(a)(1)(B) ; Akins v. State (1998) 61 Cal.App.4th 1, 17, fn. 9, 71 Cal.Rptr.2d 314.)
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