Specialty Hosps. v. Rappahannock Goodwill Indus.
Annotate this CaseRappahannock Goodwill Industries (RGI) enterd into an agreement with Specialty Hospitals of Washington. When Specialty Hospitals failed to perform under the agreement, RGI filed a complaint against Specialty Hospitals, asserting claims for breach of contract, conversion, and quantum meruit. No responsive pleadings were filed on behalf of Specialty Hospitals, and the circuit court entered default judgment in favor of RGI. Specialty Hospitals then filed a motion to set aside the default judgment, alleging that service of process was defective, that RGI's claims were against a different entity, and that RGI had erroneously sued Specialty Hospitals. The circuit court denied the motion. The Supreme Court affirmed, holding that the circuit court did not err by (1) failing to find actual notice to Specialty Hospitals, and (2) failing to consider all the factors set forth in Va. Sup. Ct. R. 3:19(d)(1).
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