California, United States of America
The following excerpt is from Nicholson v. Mohamed, B238392 (Cal. App. 2012):
Unlike the defendants in Yarbrough v. Superior Court, supra, 39 Cal.3d 197, and Payne v. Superior Court, supra, 17 Cal.3d 908, who acted in pro per. when they filed their respective motions, defendants here were represented by counsel in the filing and appearance at the hearing on defendants' motion for relief from default. Defendants had legal representation for the purpose of justifying defendants' failure to appear at the OSC hearing.
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