In In re Marriage of Askmo (2000) 85 Cal.App.4th 1032, the wife filed a petition for custody and visitation in New York. The husband then filed a California action for dissolution of marriage. When the wife could not obtain California counsel and did not answer the California action, her default was entered. The husband obtained a default judgment. The wife then filed two motions to set aside default judgment. In a March 29, 1999, order, the trial court set aside the default judgment, except as to status, but denied without prejudice the request to set aside the wife's default. The husband appealed the March 29, 1999, order. Wife then filed an ex parte order for child custody, child support, visitation, spousal support, attorney fees and costs. The trial court issued a pendente lite order awarding wife spousal support and some attorney fees. Husband again appealed contending the superior court could not issue the pendente lite order because the wife's default had been taken. The appellate court disagreed and concluded that, pursuant to Family Code section 3600, the trial court was permitted to issue pendente lite orders. ( Id. at pp. 1036-1039.)