I have just been served with a Bill of Review on a Protective Order which was granted by default. The basis of the BOR is that the return of service was filed 7 days before the default was taken and TRCP 107 requires that "no default judgment shall be granted in any cause until the citation....with proof of service....shall have been on file with the clerk of the court ten days....." However, since P.O. hearings must be set within 14 days of filing, we would rarely have a return of service on file for 10 days (exclusive of filing and hearing dates) before the hearing date. I am wondering if anyone else has had this problem and, if so, how you addressed it.