this case until 09 / 2012 , I was served w / discovery requests , ( interrogatories , prod of docs , request for admissions . ) & ignored them all . X - C filed request for order to provide discovery against me and I ignored that too . I was sanctioned and X - C request for admissions granted last 09 / 2012 admitted that all of the damages X - C requested were fair and reasonable , that all of the causes of action are true . On 12 / 19 / 2012 , X - C got a court default judgment against me for $ 400k . How do I set aside default filed on 08 / 2011 & court judgment entered by judge on 12 / 19 / 2012 . . . for excusable neglect , surprise mistake inadvertence ? Has too much time passed to set aside either defaults ? I was aware of all proceedings & X - C did it all by the book judge warned me to get an attorney ?