Default Judgment Principles Did Not Apply To Fee Recovery.
In Eftekhari v. Ford, Case No. B271555 (2d Dist., Div. 5 Mar. 14, 2017) (unpublished), plaintiff won $8,125 in attorney's fees against defendant in a civil harassment proceeding based on a fee-shifting statute. On appeal, defendant argued the trial judge lacked authority to award fees because they were not requested in the TRO paperwork. The 2/5 DCA disagreed, because the only authority cited related to default judgment matters rather than proceedings where due process was accorded to all. Nothing prevented the winner from moving for fees in the context of this case.