California, United States of America
The following excerpt is from Parish v. Peters, 1 Cal.App.4th 202, 1 Cal.Rptr.2d 836 (Cal. App. 1991):
Because plaintiffs' complaint sought only unspecified damages, it could not serve the function of a statement of damages. (Hamm v. Elkin (1987) 196 Cal.App.3d 1343, 1347, 242 Cal.Rptr. 545.) And because defendant did not receive the proper notice of the amount of damages sought, the default judgment cannot stand.
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