Midwest Developers v. Goma Corp
In Midwest Developers v. Goma Corp., 121 Wis. 2d 632, 360 N.W.2d 554 (Ct. App. 1984), the court granted default judgment as a sanction for the defendants' non-cooperation. Id. at 650. The plaintiff made no proof of damages. See id. at 651.
The Court concluded that no proof was necessary because the defendants had been made aware of the plaintiff's claim earlier in the action, and the defendants had not questioned the amount of damages. See Midwest Developers, 121 Wis. 2d at 652-53.