A defaulted defendant (or in this case, one against whom terminating discovery sanctions had been entered) may, nevertheless, move for a new trial on the ground that the court made an “error in law” in calculating damages.  Even a defaulting defendant may appeal the resulting default judgment on the grounds that the damages award (1) “is so disproportionate to the evidence as to suggest that the verdict was the result of passion, prejudice or corruption” (Uva v. Evans (1978) 83 Cal.App.3d 356, 363 (Uva)), (2) “is so out of proportion to the evidence that it shocks the conscience of the appellate court” (ibid.), or (3) is “contrary to law” (see Lasalle v. Vogel (2019) 36 Cal.App.5th 127, 139).  There is no reason why a defaulted defendant should not be able to move for a new trial on the same grounds.