Pak

BACKGROUND

In her complaint, Clara Pak (respondent) alleged that appellant failed to repay debts incurred between May 2011 and November 2013. Respondent alleged that appellant owed respondent $70,400 based on an oral agreement to make monthly payments. On February 25, 2014, respondent filed the complaint. On March 4, 2014, respondent filed her proof of service of the summons and complaint on appellant as of March 2, 2014, via substitute service on Steven Chon. Twelve days following service of process, appellant filed a grant deed transferring title to her house to her husband, Jaeis S. Chon.1 On June 20, 2014, the trial court entered a default judgment against appellant in the amount of $70,944. More than six years later, on August 12, 2020, respondent initiated the enforcement of default judgment by having a writ of execution issued.

Jaeis S. Chon’s legal name on his driver license is “Jaeis Steve Chon.”

2 On September 22, 2020, appellant filed her “Motion to Set Aside Void Entry of Default and Default Judgment and to Quash Service of Summons,” accompanied by points and authorities and declarations from appellant and her husband, Jaeis Steve Chon (Chon).2 Appellant…