Can you provide me with constructive arfuments for a motion to vacate under WI stats 806.07(2) (d) and (h) to be heard on appeal from a tpr. The argument is that the TPR orders are void ab initio based on the fact that the CHIPS Action was void ab initio for lack of due process and personal jurisdiction. The Appellate defaulted in the CHIPS Case for non appearance, motioned to vacate in the trial court and had no attorney therefore new no rights to appeal of the denied motion to vacate. Appellate was never named as a respondent to the petition or in the CHIPS Case before Dispositional defaulting him