Parking Concepts, Inc. v. Tenney, 207 Ariz. 19, 20 n. 1, ¶ 3, 83 P.3d 19, 20 n. 1 (2004). 2 . Titan does not argue that evidence of comparative fault should be allowed at a default damages hearing based on traditional default law and procedure. Cf. Postal Ben. Ins. Co. v. Johnson, 64 Ariz. 25, 33, 165 P.2d 173, 178 (1946) (default constitutes judicial admission of well-pleaded facts in the complaint). Rather, Titan’s position is based on the Helme/Morris line of cases establishing the need for a reasonableness hearing under certain circumstances. We note in passing that some jurisdictions have found that the advent of comparative fault has altered the traditional scope of a damages hearing following a default. See Burge v. Mid-Continent Cas. Co., 123 N.M. 1, 933 P.2d 210, 217 (1996) (<HOLDING>); Schaub v. Wilson, 969 P.2d 552, 558-60
holding that for a legal malpractice claim to accrue a plaintiff need not know the precise extent of his or her damages or even have suffered all of the damages attributable to his or her attorneys negligence holding that a defaulting party admits only to the liability of his or her portion of the damages and therefore what must be determined after the entry of default is the dollar amount of the damages suffered by the injured party and the portion of those damages to be awarded against the defaulting party based upon the extent of its percentage of negligence holding that the constitutional level of punitive damages is not a finding of fact that must be determined by the jury it may be determined de novo by the court holding that any doubt as to the propriety of granting relief must be resolved in favor of the party when the party is not responsible for the error that caused the default judgment holding that where a party establishes the fact of damage the facts and circumstances of the case can be put before the jury in order to enable them to estimate and fix the amount of damages to be awarded