Schremp v. Marvel
In Schremp v. Marvel, 405 A.2d 119, 121 (Del. Super. 1979), the Court measured reasonableness by comparing the amount of time that had passed (i.e., time of the defaulting party's actual knowledge of final judgment to time of filing of the motion) to the mandatory time for appealing an adverse judgment (thirty days), moving for a new trial (ten days), or reargument (five days). Id.
The court found the motion to vacate default judgment untimely when the plaintiff filed it two months after learning of the dismissal of the case. Id.
Consequently, the Court must examine the facts of each case to determine whether the moving party acted reasonably.