Background

On January 14, 2015, plaintiff Jose Orellana filed a complaint against Froilan C. Grajeda dba KKV Transport and Does 1 through 20 for seven counts of wage and hour violations and related penalties under the Labor Code, unfair competition, and conversion. Plaintiff now requests a court judgment against defendant in the principal amount of $149,693.74 plus interest, costs, and fees for a total of $179,236.13.

Procedural Requirements

On July 26, 2016, default was entered against defendant by Court order. No pending motion to vacate default appears in the record. The default judgment packet includes a request for dismissal of the Doe defendants and a proposed form of judgment on the appropriate Judicial Council form. Plaintiff’s counsel signed a declaration of nonmilitary status. The complaint prays for judgment in excess of $300,000 across several categories of principal damages actually totaling $138,213.70 plus $100,000 in penalties under Labor Code section 2699, subd