Default Judgments:  2/1 DCA Determines In Unpublished Decision That Default Judgment Cannot Include Attorney’s Fees Not Contained In A Complaint And Not Specified In Amount In A Request For Entry of Default

This Is Consistent With Our October 21, 2025 Post On A 4/2 DCA Unpublished Opinion To The Same Effect.

In Paragon Six, LLC v. Girgis, Case No. B327441 et al. (2d Dist., Div. 1 Oct. 31, 2025) (unpublished), the 2/1 DCA reversed an attorney’s fees contained in a default judgment because fees were not requested in the Complaint and no specific amount of fees were set forth in the Request for Entry of Default, relying on Garcia v. Politis, 192 Cal.App.4^th 1474, 1481 (2011).  This result is consistent with our October 21, 2025 post on Chardonnay Hills Homeowners Assn. v. Hoffman, a 4/2 DCA unpublished opinion coming to the same result.