A plaintiff alleging an accounting action must plead a specific dollar amount to support a default judgment awarding monetary relief.  The complaint can plead an estimated amount of damage and can err on the high side.  The decision does not resolve how the maximum default recovery is to be calculated if the complaint’s prayer does not distinctly request award of a specific sum as total damages but the substantive allegations of the complaint mention sums sought or damages incurred as to specific claims–i.e., whether the amount of relief should be calculated on a claim-by-claim (or item-by-item) basis or an aggregate basis.