Request To Enter Default Judgment Must Include Attorney Fees; They May Not Be Awarded On Motion Following Entry Of Judgment.

When seeking a default judgment, plaintiff indicated in his form declaration he was seeking damages and costs. After the court entered the default judgment, plaintiff filed a noticed motion seeking an award of attorney fees as authorized under the applicable statute. The trial court denied the motion and the Court of Appeal affirmed. A default judgment includes all of the relief plaintiff may recover. Garcia v. Politis (Cal. App. Second Dist., Div. 4; February 25, 2011) 192 Cal.App.4th 1474, [122 Cal.Rptr.3d 476].