California, United States of America
The following excerpt is from City of Fontana v. Bani, LLC, E062018, E063549 (Cal. App. 2016):
"What these two subdivisions make clear is that a party seeking entry of a default judgment must apply for all of the relief sought including attorney fees when application is made for entry of default." (Garcia v. Politis, supra, 192 Cal.App.4th at pp. 1478-1479.)
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