Motion for Equitable Relief and to Vacate a Judgment [Memorandum of Points & Authorities]

Motion for Equitable Relief and to Vacate a Judgment [Memorandum of Points & Authorities] with supporting authorities for the arguments including, inter alia statutory relief barred; public policy considerations favor relief, petitioner was denied a full and fair hearing, petitioner not seeking a retrial, judgment is void; good cause for relief; equitable relief not barred, petitioner’s fraud nor mistake procured the judgment, relief not barred by statute of limitations, estoppel, laches; relief should be granted on the grounds of extrinsic fraud or mistake, fraud on the court; petitioner diligent in seeking relief, has a meritorious case, is entitled to relief; court has discretion to vacate the order; court’s findings are controlling and presumed correct, would not effect an injustice. 28 pages.