California, United States of America
The following excerpt is from Grappo v. McMills, 11 Cal.App.5th 996, 240 Cal.Rptr.3d 164 (Cal. App. 2017):
or against a person not a party. Hence, it seems clearly in excess of jurisdiction and subject to prevention or annulment by some form of direct attack. (See Boyd v. Lancaster (1939) 32 [Cal.App.2d] 574, 581 [90 P.2d 317] [reversal on appeal: The defect would appear to us to go to the jurisdiction
[11 Cal.App.5th 1008]
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