What is the range of damages available to a plaintiff in a personal injury case when a default judgment is entered?

Further, there is no miscarriage of justice. Code of Civil Procedure section 580 limits the relief available on default to that which was "demanded in the complaint." Appellant's TAC does not demand any specific amount of monetary damages.⁴ Code of Civil Procedure section 425.11 requires that a plaintiff in a personal injury case give notice to a defendant in the form of a statement of damages prior to entry of a default. (Code Civ. Proc., 425.11, subd. (b), (c).) A default judgment is void if no statement of damages is served before a default is entered. (Stevenson v. Turner (1979) 94 Cal.App.3d 315, 318.) Appellant does not assert that he served on any defendant a statement of damages prior to the entry of the default in this matter. Thus, the default was void.