When a defendant doesn’t bother to defend himself against a lawsuit, the plaintiff can get a default judgment for punitive damages only if the plaintiff serves the defendant with a statement of the amount of punitive damages sought.  (See Code of Civil Procedure section 425.115.)  In this case, the plaintiff got a default judgment for $25,000 in punitive damages, but never served a statement of damages.  An easy reversal, right?  Not so fast.  The default judgment in this case was entered way back in 1990, well before the Legislature enacted the statute requiring a statement of damages (which happened in 1992).  Accordingly, the California Court of Appeal (Second Appellate District, Division Two) affirms in an unpublished opinion.