McEwen Lumber Co. v. Lipscomb Bros. Lumber Co.

Under Rule 1:1, a final judgment remains under the control of the trial court “for twenty-one days after the date of entry, and no longer.” Code § 8.01-428(A), however, provides:

Default judgments and decrees pro confesso; summary procedure. — Upon motion of the judgment debtor and after reasonable notice to the opposite party, his attorney of record or other agent, the court may set aside a judgment by default or a decree pro confesso upon the following grounds: (i) fraud on the court, (ii) a void judgment, (iii) on proof of an accord and satisfaction. Such motion on the ground of fraud on…