California, United States of America
The following excerpt is from Franklin & Seidelmann, Inc. v. Chao, D065195 (Cal. App. 2014):
When the motion to vacate the default is denied before entry of the default judgment, "the order denying the motion to vacate the default is not independently appealable," but rather may be reviewed only "on an appeal from the judgment." (Rappleyea v. Campbell (1994) 8 Cal.4th 975, 981.) The issue here is whether we have jurisdiction to review entry of the default when the denial of the motion to vacate the
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default occurs after entry of the default judgment and there is no appeal from the judgment.
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