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Once a defendant meets the first two factors in the Craddock test, the burden shifts to the plaintiff who must show that vacating the default judgment would cause undue delay or injury.

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No judgment may be taken by default against the adverse party in the court to which the case has been appealed without first showing substantial compliance with this rule.

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Chances of vacating a default judgement and receiving a new trial are generally very high.

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In appropriate circumstances a party may need to submit a sealed document for consideration by the court.

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