In Villarruel v. Arreola (1977) 66 Cal.App.3d 309, the court's endorsement of an appearance by a "stranger to the action" was in reference to an excess insurer against whom the plaintiff proceeded after obtaining a consent judgment of which the insurer had no notice. (Id. at p. 317.) The insurer was directly affected by the consent judgment, which appeared to have been entered "as a result of mistake, or collusion, or fraud." (Ibid.) Indeed, the court held, "it is patent that the interests of the insurer, although a stranger to the action, were substantially and intentionally affected by the judgment." (Ibid.)