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

A party's default conclusively establishes that party's liability, however it does not establish the amount of damages. Geddes v. United Fin. Group, 559 F.2d 557, 560 (9th Cir. 1977) (per curiam). Where damages are liquidated, i.e., capable of ascertainment from definite figures contained in documentary evidence, or in detailed affidavits, judgment by default may be

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