What is the test for default judgment in a personal injury case?

"Default judgment is a procedural device designed to clear the court's calendar and files of those cases which have no adversarial quality. In order to reach the default stage, a party must follow certain well-defined rules which ensure that a defendant has sufficient knowledge of the pending action. Of course, a defendant may choose to vigorously defend or simply ignore the plaintiff's claims. The rules governing default judgment provide the safeguards which ensure that defendant's choice is a fair and informed [221 Cal.App.3d 1310] one. [p] Because default judgment ends the controversy, the rules leading to it are precise and should be followed to the letter. Where a plaintiff fails to adhere to those rules, a defendant need not suffer the consequences a default judgment brings." (Jones v. Interstate Recovery Service (1984) 160 Cal.App.3d 925, 928, 206 Cal.Rptr. 924 .)

Section 425.11 provides that before a default can be taken, a plaintiff "shall give notice to the defendant" of the amount of special and general damages sought. This statute "operates in conjunction with ... section 425.10, subdivision (b), which mandates that a complaint for damages resulting from personal injuries shall not state the amount of damages sought. The purpose of the latter statute is to protect defendants from adverse publicity resulting from inflated demands. [Citation.] Section 425.11 was designed to give defendants 'one last clear chance' to respond to allegations of complaints by providing them with 'actual' notice of their exact potential liability. [Citation.]" (Original emphasis; Connelly v. Castillo (1987) 190 Cal.App.3d 1583, 1588, 236 Cal.Rptr. 112.)