PRETRIAL ADJUDICATION
...Default
......Default Judgment
.........Attorney's Fees
2 Cards On This Topic:

Plaintiff electing to proceed via default judgment may recover statutory attorney fees only if a request for those fees is included in the request for default judgment.

Atty. fees awarded did not constitute the type of "relief" that must be stated by amount in the complaint to be recovered in a default judgment entered as discovery sanction.