In Sanders v. Cseh, et al., (Del. Super., Sept. 22, 2006), read opinion here, the Delaware Superior Court addressed the standard under Rule 60(b) that needs to be satisfied before a default judgment will be vacated due to "excusable neglect" or related reasons under the rule. The court had no sympathy for the insurance company that missed the deadline by more than 18 months, for an answer to be filed.

This is a useful case to have in the toolbox of a business litigator. Hopefully it would only be needed in order to defend a Rule 60(b) motion instead of filing one.