LAW.coLAW.co

All Restored Inc. v. Orzechowski

2026-08-20

Summary

Holding. The court denied the defendant's motion to reopen proceedings and vacate the default judgment, finding that the defendant failed to demonstrate excusable neglect under Rule 60(b) where she had actual notice of service in August 2025, acknowledged receiving paperwork at the hearing, and later failed to appear for the rescheduled hearing despite being properly notified.

All Restored Inc. sued Christine Orzechowski, a pro se defendant, and obtained a default judgment after Orzechowski failed to respond to the complaint. Months later, Orzechowski requested a stay of a pending sheriff's sale, which the court granted and treated as a motion to vacate the default. At a July 10, 2026 hearing, Orzechowski claimed she had never been properly served, but during that same hearing she acknowledged receiving paperwork in August 2025 and admitted owing the money at issue. The court rescheduled the hearing for July 15, but Orzechowski failed to appear and did not respond to the confirmation email. She later sought relief, attributing her absence to not seeing the email and citing a car accident from the prior hearing date.

The court applied the legal standard for relief from judgment under Rule 60(b), which requires a showing of excusable neglect followed by analysis of meritorious defense and prejudice. The court found that Orzechowski's own statements at the hearing contradicted her claim that she was never served—she had received papers in August and even emailed opposing counsel about them. The court further noted that Orzechowski's failure to check email or contact the court after agreeing to a rescheduled hearing on July 15 did not constitute excusable neglect. Additionally, even if relief were warranted, Orzechowski had admitted owing the underlying debt, defeating any meritorious defense.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether service of process was properly effectuated on the pro se defendant
  • Whether the defendant's neglect in missing the rescheduled hearing was excusable under Rule 60(b)
  • Whether the defendant had a meritorious defense to the underlying debt

Procedural posture

The defendant's motion to reopen proceedings and vacate the default judgment was decided by the Superior Court following a hearing on July 10, 2026, where the defendant requested continuance due to a parking lot accident and later failed to appear for the rescheduled July 15 hearing.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

ALL RESTORED INC., )

)

Plaintiff, )

)

v. ) C.A. No. N25L-08-005 SSA

)

CHRISTINE ORZECHOWSKI, )

)

Defendant. )

)

)

)

Submitted: August 5, 2026

Decided: August 20, 2026

On Defendant’s Motion to Reopen Proceedings

Delaware favors hearing matters on the merits. But the law does not permit a

litigant to ignore the process. Mindful that this Defendant is a pro se litigant, this

Court has sought to afford her an opportunity to be heard. However, “[t]here is no

different set of rules for pro se plaintiffs, and the trial court should not sacrifice the

orderly and efficient administration of justice to accommodate an unrepresented

plaintiff.”1

Procedural History

A Complaint was filed on August 1, 2025, in this matter. 2 On August 27,

2025, the Sheriff indicated that Ms. Christine Orzechowski, the Defendant, had been

1

Draper v. Med. Ctr. of Del., 767 A.2d 796, 799 (Del. 2001).

2

See Compl., D.I. 1.

personally served.3 She did not file an answer or other responsive motion. On

October 22, 2025, Plaintiff sought default judgment pursuant to Superior Court Civil

Rule 55(b)(1). 4 Still the Court did not hear from Defendant.

In June of this year, the Court received Defendant’s request to stay an

imminent sheriff sale, which alleged she was “not served with enough time….”5

Recognizing the potential irreparable harm to Defendant, the Court granted that

Motion and stayed the sheriff’s sale pending the matter’s resolution.6 Plaintiff

treated the Motion as one to vacate default judgment and filed a response. 7 The

Court then directed Defendant to file a written response and set a hearing date.8

In her written response, Defendant asserted that she had never been personally

served with the Complaint; she told the Court the “first notice of any legal

proceedings concerning this matter occurred on June 2, 2026….” 9 If true, such an

assertion would warrant further inquiry.

Plaintiff’s counsel filed a reply, attaching an email he received from

Defendant on September 17, 2025, regarding the “paperwork [she] was served[.]”10

3

See Sheriff’s Return, D.I. 4.

4

See Direction for Default J., D.I. 6.

5

Mot., D.I. 16.

6

Order, D.I. 17.

7

Pltf.’s Opp’n to Def.’s Mot., D.I. 19.

8

Letter, D.I. 20.

9

Def.’s Response, D.I. 22, at 1, 2.

10

Pltf.’s Reply to Def.’s Response, D.I. 23, Ex. 2.

The Court scheduled a hearing for July 10, 2026.11 On that date, Defendant arrived

late. She advised the Court she had been in an accident in the courthouse parking

lot. Seeing that she appeared distracted, the Court asked if she needed a continuance.

Defendant initially declined; she told the Court she was fine but perhaps had an

injury to her arm.

However, as the hearing proceeded, Defendant requested a continuance.

While rescheduling, the Court sought to clarify the legal issues and standards for

when the matter reconvened. At this point, Defendant proffered that she had been

served with “paperwork last August….” 12 She also stated “I agree that I owe

money.”13

Before the July 10 hearing ended, the Court advised Defendant the

rescheduled hearing would likely take place on July 15, 2026, and she would receive

a confirmatory email from Chambers. That same day, Chambers sent an email to

the same email address Defendant previously had used to communicate with the

Court.14 The following week, Defendant failed to appear. She did not contact the

Court via email or phone call. The Court deemed the Motion to Vacate Default

Judgment withdrawn.15

11

See generally Mots. Hr’g Tr., D.I. 33; Judicial Action Form, D.I. 24. 12

D.I. 33, at 12:13.

13

Id. at 14:17.

14

See D.I. 26. See also D.I. 25.

15

Judicial Action Form, D.I. 27.

Five days later, without acknowledging her missed Court date, Defendant

wrote to request “a continuance of the hearing … due to significant and unforeseen

medical circumstances….”16 She cited her July 10 car accident as the reason for her

belated request. The Court responded by letter, advising that judicial action must be

initiated by motion with supporting documents.17

Eventually, on August 5, 2026, this Court received a Motion from Defendant,

asking the Court to “reopen proceedings, vacate prior orders, and stay sheriff’s

sale.” 18 Regarding missing the July 15, 2026 hearing, Defendant stated “she did not

see the email” confirming the rescheduled date.19 She asserted she has “acted in

good faith throughout these proceedings” and has a bona fide dispute regarding

whether she received service of process.20

Legal Standards

Rule 60(b) governs a motion for relief from judgment. The Rule states, in

relevant part:

On motion and upon such terms as are just, the Court may relieve a

party or a party’s legal representative from a final judgment, order, or

proceeding for the following reasons: (1) Mistake, inadvertence,

surprise, or excusable neglect[.]

16

D.I. 29, at 1.

17

Letter, D.I. 30.

18

D.I. 32.

19

Id. at 4.

20

Id. at 3, 4.

This inquiry takes several steps. It first involves an analysis of whether the

defendant’s culpable conduct led to default, and if so, whether it was excusable.21

The law has defined “excusable neglect” in this Rule’s context as “neglect which

might have been the act of a reasonably prudent person under the circumstances.”22

The burden in this case is on the Defendant to demonstrate her “neglect was

excusable.”23 If the neglect was not excusable, then this Court will not analyze the

additional factors. 24 But, if excusable, the next question is whether there is a

meritorious defense. 25 Finally, the Court asks whether the plaintiff will suffer

prejudice.26

Analysis

This Court does not have the discretion to ignore the record or the law. On

July 10, Defendant verbally volunteered to this Court that she had been served.

Additionally, there is record evidence that she emailed Plaintiff’s counsel regarding

the Complaint, after being served. Therefore, there is no dispute regarding service

of process.

21

Apartment Cmtys. Corp. v. Martinelli, 859 A.2d 67, 69 (Del. 2004) citing Farnese v. Bagnasco, 687 F.2d 761, 764 (3d Cir. 1982).

22

Id. at 70 (citation omitted) quoting Battaglia v. Wilmington Sav. Fund Soc'y, 379 A.2d 1132, 1135 n.4 (Del. 1977).

23

Id. at 72 citing Cohen v. Brandywine Raceway Ass'n, 238 A.2d 320, 324 (Del. Super. Ct. 1968).

24

Id. at 70, 72.

25

Id. at 69–70 (citation omitted).

26

Id. at 70 (citation omitted).

Defendant’s written filings do not change this fact. Understanding that

litigants seek to advance their position advantageously, her written assertions give

the Court concerns regarding candor. Defendant had notice of the lawsuit last

August, which is precisely when the Sheriff verified personal service.

While not germane to the central legal question, Defendant’s belated

continuance request of the hearing suggests similar issues with inaction. Following

the July 10 continuance due to her car accident, Defendant knew the Court was going

to reschedule a hearing—likely on July 15—to accommodate her Motion to Vacate

Default Judgment. It is difficult to understand why Defendant did not check her

email or reach out to the Court. Undoubtedly, this is a matter of significance to

Defendant, yet she failed to appear or communicate.

The Court finds no excusable neglect justifying relief under Rule 60(b). Even

though the Court’s analysis stops where there is no such finding, Defendant further

could not establish a meritorious defense to the Complaint where she agreed she

“owes the money.”

Therefore, the Motion to Reopen Proceedings is DENIED.

IT IS SO ORDERED.

/s/Sonia Augusthy

Judge Sonia Augusthy