Sample California Complaint in Equity to Vacate Judgment

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This sample California complaint to set aside and vacate a judgment is filed as a collateral attack on a judgment also known as an independent action in equity to vacate a judgment. The sample contains two causes of action (1) to set aside and vacate the judgment on the grounds of lack of personal jurisdiction due to defective and invalid service of process, and (2) to set aside and vacate the judgment on the grounds that it was procured through  extrinsic fraud or mistake. The sample is 7 pages and includes brief instructions.  The author is a freelance paralegal who has worked in California and Federal litigation since 1995. Note that the author is NOT an attorney and no guarantee or warranty is provided.