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In Texas, this must be filed within 14 days of the judgment. Essentially, in a motion to vacate, you would be giving the Court a reason to set aside the judgment and keep the lawsuit active. If the Court thinks the reason you have given is a good one, the judgment will be vacated.
Understanding Personal Jurisdiction in Texas A court without personal jurisdiction over the defendant has no authority to adjudicate the case filed by the plaintiff. The defendant is under no obligation to respond to the lawsuit filed in a court lacking personal jurisdiction.
A special appearance in court is distinct from general appearances in that it is made solely to challenge jurisdiction. A special appearance must be filed prior to a motion to transfer venue or any other general appearance (such as a plea, hearing, or motion).
192.3 Scope of Discovery. (a)Generally. In general, a party may obtain discovery regarding any matter that is not privileged and is relevant to the subject matter of the pending action, whether it relates to the claim or defense of the party seeking discovery or the claim or defense of any other party.
FRCP Rule 12: All 7 sub-sections of 12(b) may be used as grounds for a motion for dismissal. These include dismissals for: (b)(1) a lack of subject-matter jurisdiction. (b)(2) a lack of personal jurisdiction.