Yes this can be done, it would be best if done by a notarized stipulation. A default could always set aside. A notarized stipulation would cost a little more but the protection would be worth the few extra dollars of paying his filing fee.
My name is Stephen R. Cohen and have practiced since 1974. I practice in Los Angeles and Orange County, CA. These answers do not create an attorney client relationship. My answers may offend I believe in telling the truth, I use common sense as well as the law. Other state's laws may differ.. There are a lot of really good attorneys on this site, I will do limited appearances which are preparation of court documents it is , less expensive. However generally I believe an attorney is better than none, but many will offer a free consultation and a face to face meeting generally will be better, I like my clients to write a short one page history of the fact and questions they have prior to meeting with them, so nothing is forgotten.
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