Vinayagam

I. BACKGROUND

On August 8, 2014, Vinayagam filed a complaint against Shravan Debbad and NRISoft, Inc. alleging claims for intentional misrepresentation, negligent misrepresentation, concealment, and false promise. After earlier unsuccessful attempts, the complaint was personally served on January 8, 2016. Default was entered as to Debbad on April 11, 2016, and as to NRISoft on May 9, 2016. In December 2017, Vinayagam requested the court enter a $1.8 million judgment in her favor. The court rejected this request, explaining in part that the complaint did not provide notice of damages in any amount and that Vinayagam was required to file and serve an amended complaint providing this notice. The court explained that doing so would open the default and give defendants a new opportunity to answer the complaint. On March 21, 2018, Vinayagam’s counsel filed a first amended complaint alleging the same causes of action but specifying that Vinayagam sought at least $342,618.13 in special damages and at least $500,000 in general damages. Thereafter, Vinayagam’s attorney sought to be relieved as counsel based on “an irreconcilable breakdown in the attorney-client relationship.” The court…