What is the test for a plaintiff to recover damages for personal injury?

to recover damages for personal injury, the amount of damages claimed may not be stated in the complaint. ( 425.10, subd. (b).) Instead, the defendant "may at any time request a statement setting forth the nature and amount of damages being sought. ( 425.11, subd. (b).) If the defendant does not make such a request, "the plaintiff shall serve the statement on the defendant before a default may be taken." ( 425.11, subd. (c).) Thus, "[n]ot only is a default judgment for an amount greater than that specifically demanded void, but when a statement of damages is required but not served, the underlying entry of default is invalid also and is subject to set-aside." (Van Sickle v. Gilbert (2011) 196 Cal.App.4th 1495, 1521.)