What Are the Consequences of Document Alteration or Destruction That

Greg sues Ned in an effort to get title to some land claimed by Ned and located inside the state of Texas.Ned has never been to Texas in his life,has never had any contacts of any kind with the state,and refuses to appear in Texas to defend against Greg's suit.Later,after Greg wins a default judgment against Ned,Ned shows up in Texas to claim that the judgment was invalid because he was totally outside Texas,hence Texas courts had no jurisdiction over him,and for this reason they could not affect his rights to the land.Is Ned right? Why or why not? Assume that subject-matter jurisdiction exists.

Dee sues Gerry for defamation.Dee thinks that the facts clearly are not as stated in Gerry's complaint and that,given Dee's version of the facts,Gerry cannot recover for defamation.What motion gives Gerry the best chance of winning the case early? What does it involve?