The following excerpt is from Gregorian v. Izvestia, 871 F.2d 1515 (9th Cir. 1989):
We have stated that a defendant's conduct is culpable if he has received actual or constructive notice of the filing of the action and failed to answer. Meadows v. Dominican Republic, 817 F.2d 517 (9th Cir.), cert. denied, --- U.S. ----, 108 S.Ct. 486, 487, 98 L.Ed.2d 485 (1987). Defendants do not dispute the fact that they had notice of the action. Their conduct thus appears at first glance to be "culpable." However, this case is distinguishable from those cases in which we have found a party's conduct to be culpable.
1. "Culpable Conduct"
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