The Second Appellate District affirmed a judgment. The court held that a plaintiff seeking attorney’s fees incurred in prosecuting its complaint was not required to specify the amount of those fees at the time of filing in order to recover them later as part of a default judgment.

Jerry and George Athans and others retained the law firm of Simke, Chodos, Silberfeld & Anteau, Inc. to represent them in litigation. The parties’ retainer agreement provided that in the event of a dispute arising from the agreement, the prevailing party would be entitled to attorney’s fees.