satisfies the “actually litigated” requirement for the application of collateral estoppel. Lake, 202 B.R. at 757 & n. 6; Green, 198 B.R. at 566 (citing Four Star Elec., Inc. v. F & H Constr., 7 Cal.App.4th 1375, 10 Cal.Rptr.2d 1, 5 (1992)). 2. Extrinsic Fraud Debtors contend in their opening brief that the bankruptcy court should not have given preclusive effect to the default judgment because Debtors’ failure to appear was due to opposing counsel’s “fraud” and misrepresentations to them. A state court judgment is subject to collateral attack if the judgment was procured by extrinsic fraud. Lake, 202 B.R. at 758. Extrinsic fraud is an exception to the application of the full faith and credit doctrine such that a judgment procured by fraud may be disregarded by the bankruptcy court. Id. (<HOLDING>); In re Naemi 128 B.R. 273, 279
holding that the district court had subject matter jurisdiction to hear the petitioners collateral attack under  1331 recognizing collateral attack on void order holding that a judgment as to the title in a prior litigation was not subject to collateral attack recognizing bankruptcy courts jurisdiction over such a collateral attack holding that district courts do not have appellate jurisdiction over state courts