Affinity Health Partners, LLC v. Hayes Locums, LLC
After a clerk's default, the trial court entered a final default judgment for over $219,000 based only on a service agreement and a one-page invoice summary, with 25 days' notice of a five-minute non-evidentiary hearing. The Fourth DCA reversed, holding the damages were unliquidated because the contract set no rates (fees were fixed in separate unattached 'Confirmations') and the complaint alternated among differing damage figures, so a properly noticed damages trial under Rule 1.440 was required.
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