Iliff v. Dustrud

In Iliff v. Dustrud (2003) 107 Cal.App.4th 1201, appellant argued the respondent's motion to set aside the judgment was untimely under section 683.170. The Fourth District held that because appellant did not cite that section to the trial court, but rather relied on section 473, subdivision (d), appellant had waived the argument of timeliness under section 683.170. (Iliff, at p. 1206.)