California, United States of America
The following excerpt is from Page v. Park, B293993 (Cal. App. 2020):
defense]; Carney v. Simmonds (1957) 49 Cal.2d 84, 95 [an independent action attacking a judgment on the grounds of extrinsic fraud is allowed where it appears that there was a willful failure to give service or that willfully false affidavits of service were filed]; County of San Diego v. Gorham (2010) 186 Cal.App.4th 1215, 1226-1227 [a default judgment entered against a defendant who was not served with a summons in the manner prescribed by statute to establish personal jurisdiction is void].)
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