What is the test for serving a statement of damages in a motor vehicle accident case?

"When a complaint is filed in an action to recover damages for personal injury or wrongful death, the defendant may at any time request a statement setting forth the nature and amount of damages being sought." ( 425.11, subd. (b).) "If no request is made for the statement referred to in subdivision (b), the plaintiff shall serve the statement on the defendant before a default may be taken." (Id., subd. (c).) "If a party has not appeared in the action, the statement shall be served in the same manner as a summons." (Id., subd. (d)(1).) Where a default results from the striking of a party's pleading due to a discovery violation, the statement of damages must be served as if the party had not appeared in the action. (Greenup v. Rodman (1986) 42 Cal.3d 822, 825-829 [when a

Page 9