California, United States of America
The following excerpt is from Leontaritis v. Koursaris, B219095, Los Angeles County Super. Ct. No. BC383073 (Cal. App. 2011):
When a defendant claims a default and default judgment are void for lack of personal jurisdiction due to invalid service of process, the burden is on the plaintiff to prove the service of process was valid. (Summers v. McClanahan (2006) 140 Cal.App.4th 403, 413.) We review de novo the question whether service of process was valid. (Hearn v. Howard (2009) 177 Cal.App.4th 1193, 1200.)
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