an ordinary appeal had passed, leaving only a restricted appeal or a bill of review as options for seeking postjudgment relief from the default. By the time Gibbons-Markey notified TMLT, the window for filing a restricted appeal had also closed leaving a bill of review as the only option. TMLT argues that it was adversely affected during the five-month lapse because, had it learned of the default judgment contemporaneously with Markey, it could have filed a restricted appeal. We disagree. A restricted appeal (formerly called an appeal by writ of error) may be filed, within six months after the judgment or order is signed, by a party that (1) did not participate, either in person or through counsel, in the hearing that resulted in the 05 S.W.3d 286, 290 (Tex.App.-Dallas 2003, no pet.) (<HOLDING>). The courts below found persuasive TMLT’s
recognizing that a default judgment based on improper service is void holding that a default judgment was not void because the bankruptcy court that entered the judgment had proper jurisdiction over the party seeking relief holding that trial court must make entry of default prior to entry of default judgment and court may not make entry of default when there is no default in law or in fact holding that failure to serve debtors with filed complaint and issued summons rendered default judgment void holding that a defendant was estopped from asserting improper service where the defendants conduct caused the allegedly improper service