Adams v. Mallory

In Adams v. Mallory, 308 Md. 453, 460, 520 A.2d 371 (1987), Judge Couch was emphatic that, even after an order of default as to liability, a full evidentiary hearing may be required "to determine the relief to be awarded against the defaulting party." Ordinarily, the court will have to determine the relief to be awarded against the defaulting party before there is a final judgment on the claim involved in the default. Rule 2-613(e) makes this clear by providing that "if, in order to enable the court to enter judgment, it is necessary to take an account or to determine the amount of damages or to establish the truth of any averment by evidence or to make an investigation of any matter, the court may . .. conduct hearings."