Default notes

December 10, 2018

The restricted appeal case of Cate v. Posey reminds:

  • A difference in addresses noted in the record may not be material if the record also accurately establishes personal service; and
  • A CPRC § 18.001 affidavit of reasonableness can be sufficient evidence to support the damages portion of a default judgment, but not if a referenced itemized list is not included in the record.

No. 05-17-01216-CV (Dec. 4, 2018) (mem. op.)