While a plaintiff who seeks an attorney fee award must apply for the fees before entry of a default judgment, not afterwards, as in contested cases (Garcia v. Politis (2011) 192 Cal.App.4th 1474), here the defendant successfully moved to vacate the default and default judgment. At that point the case became a contested proceeding, and upon prevailing in that proceeding, the plaintiff was entitled to an award of attorney fees incurred after entry of the now-vacated default judgment.