Can a plaintiff obtain a default judgment that does not award attorney fees?

Appellants rely on Garcia v. Politis (2011) 192 Cal.App.4th 1474. There, the plaintiff obtained a default judgment that did not award attorney fees. Two months later, he filed a motion for attorney fees. (Id. at p. 1477.) The court held that the postjudgment motion was improper: "A plaintiff electing to proceed by way of a default judgment may recover statutory attorney fees only if a request for those fees is included in the request for default judgment." (Id. at pp. 1476-1477.)