What is the difference between a defaulted case and an uncontested proceeding within a case which has not been defaulted?

But, the majority hold, stipulations are required only of parties litigant, and this petitioner was not a party litigant because he failed to appear at the hearing on the order to show cause. This deduction trifles with reality. The petitioner was named in the complaint as a party litigant, he was served [13 Cal.3d 15] with summons as a party litigant, and he was not in default as a party litigant. He merely failed to contest a pendente lite order. There is a vast consequential difference, as pointed out in Mosler v. Parrington (1972) 25 Cal.App.3d 354, 357, 101 Cal.Rptr. 829, between a defaulted case and an uncontested proceeding within a case which has not been defaulted.