Taylor

This is a consolidated appeal by cross-defendants Louis W. Varga and R. Agnus Varga from a judgment by court after default entered April 8, 1992, and from an earlier order of January 22, 1992, ordering appellants and their attorneys to pay sanctions in the amount of $2,190 in connection with appellants’ motion for relief from default. A fire at appellants’ restaurant allegedly caused damage to adjacent premises, and the insurer for the adjacent premises brought a subrogation action against appellants and lessor respondents, who cross-complained against lessee appellants for indemnity. Appellants were served by publication; their default was entered; and they unsuccessfully attempted to obtain relief from default and to vacate the default. Judgment after default was entered. Appellants contest the validity of the default and the court’s orders denying relief from default, contending that the request to enter default was defective and that default could not properly be entered following service by publication.

The Chronology

On May 23, 1989, Civil Service Employees Insurance Company (Civil Service) sued appellants for subrogation. The complaint alleged that appellants…