What is the legal test for a motion to set aside a default judgment?

The Code of Civil Procedure establishes several statutory avenues to set aside default judgments.³ Section 473, subdivision (b) permits a court to set aside a judgment on the ground of "mistake, inadvertence, surprise, or excusable neglect." A motion seeking relief under this subdivision must be brought within "a reasonable time, in no case exceeding six months" after the judgment was taken. (Ibid.) Section 473.5, subdivision (a) provides that, when service of a summons "has not resulted in actual notice to a party in time to defend the action and a default or default judgment has been entered," the party may file a motion to set aside the judgment. Such a motion must be filed, at the latest, within two years after entry of the default judgment. (Ibid.) More generally, section 473, subdivision (d) permits a court to "set aside any void judgment or order." When the basis for a motion under this subdivision is that a judgment " 'though valid on its face, is void for lack of proper service, the courts have adopted by analogy the statutory period for relief from a default judgment' provided by section 473.5, that is, the two-year outer time limit." (Trackman v. Kenney (2010) 187 Cal.App.4th 175,

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