Thank you for asking for me for your follow up question. I apologize for the delay, but I have had some bad internet service connections while traveling for a client.
The claim of improper service is always a defense made to try to vacate a default judgment. If you used the warning attorney and the warning attorney properly went through the process, then this defense is generally dismissed as not being good cause or a valid defense as the documentation will show that there was an attempt at proper service which the defendant continued to avoid.
As far as the default judgment you need to check with the clerk to see why the judgment was not entered on March 20 as the court stated it would be and the judge's clerk would be th one who would have to tell you the cause for the delay on issuing that judgment.
It sounds like this defendant is merely looking to delay the case, which he has done by continually avoiding service and forcing you to get the warning attorney and this move to seek to vacate the judgment is just further delay. If the court for some rare reason for this defense does grant the vacating of the judgment this defendant will likely delay filing his answer and ask for extensions and anything else they can do to force a delay of the case and try to cost you additional money.
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