California, United States of America
The following excerpt is from Little v. Sanchez, 166 Cal.App.3d 501, 213 Cal.Rptr. 297 (Cal. App. 1985):
Any judgment not based upon a valid waiver of a debtor's due process rights is voidable at any time. As observed in Cross v. Tustin (1951) [166 Cal.App.3d 505] 37 Cal.2d 821, 825, 236 P.2d 142, "a court has inherent power to expunge a fraudulent record or set aside a decree procured by extrinsic
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