Does a party have to request statutory attorney's fees as damages in a motion or answer?

Generally, a party need not request "attorney's fees qua attorney's fees," i.e., "those attributable to the bringing of [an] action itself" (Brandt v. Superior Court (1985) 37 Cal.3d 813, 817, 210 Cal.Rptr. 211, 693 P.2d 796 ) as opposed to those sought as damages, in a complaint or answer. (See Faton v. Ahmedo (2015) 236 Cal.App.4th 1160, 1169, 187 Cal.Rptr.3d 201 [statutory attorney fees need not be pled and proven, and instead may properly be requested and awarded after entry of judgment; however, attorney fees sought

[219 Cal.Rptr.3d 854]