Dan Epps

I also don't think it totally follows that if the petitioner is right, that would mean you can't have time limits for filing appeals.

I don't know.

That didn't strike me as such a gotcha argument as the court thought it was.

Well, I mean, you might say, like, you know, due process requires there be some avenue to attack, avoid judgment, you know, forever.

It doesn't have to be the direct appeal avenue.

Yeah.

But I mean, normally, I guess the normal understanding is, you know...

Appeals happen shortly after a judgment, whereas there is this opportunity later to come back and kind of challenge the judgment.

And that's normally what we would, I guess that's if you would ask me, like, when's the time to go kind of get a judgment, you know, that was entered improperly?

Yeah.

So.

But so we don't know what's reasonable.

Reasonable could be a very long time in this context, you know, and reasonable could, for example, incorporate like concerns about notice, right?

Maybe it's a really long delay is reasonable if the defendant of the judgment does not have notice of the judgment, does not have notice of the action.

Maybe that would entitle you to have a long delay and then file as soon as you become aware.

That could be valid.

Yeah.

Nine to nine to four.

Pretty good.

Pretty good record.