California, United States of America
The following excerpt is from Sarracino v. Superior Court, 118 Cal.Rptr. 21, 13 Cal.3d 1, 529 P.2d 53 (Cal. 1974):
[13 Cal.3d 19] Barfield v. Superior Court (1963) 216 Cal.App.2d 476, 31 Cal.Rptr. 30, involved a default divorce heard by a commissioner, sitting as a temporary judge. There the court held that the defendant, whose default had been entered, was not one of the 'parties litigant' whose consent was required for the appointment of a temporary The status of a party changes drastically after the entry of his default. He
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