Hearing on Unliquidated Damages In its second point of error, appellant contends the trial court erred by not conducting a hearing on damages. Specifically, appellant contends appellees’ claims for ad valorem taxes are unliquidated claims requiring a rule 243 hearing. Appellant further contends the failure of the trial court to make a record of any eviden-tiary hearings constitutes error on the face of the record requiring reversal and remand for a new trial. Because we hold that appellees’ claims are liquidated, we overrule appellant’s second point of error. Once a default judgment is taken against a non-answering defendant, all allegations —Dallas 1994, no writ) (damages for personal injuries are unliquidated); Alvarado v. Reif, 783 S.W.2d 303, 305 (Tex.App.—Eastland 1989, no writ) (<HOLDING>). But if the claim is liquidated and proved by
holding that claim for damages based on repair estimate is not a liquidated damage holding that because liquidated damages under the adea are punitive in nature a jurys award of state punitive damages and adea liquidated damages constitutes a double recovery and therefore reducing the total recovery by the amount of the liquidated damages award holding that liquidated damages under fair labor standards act constitutes compensation for the retention of a workmans pay which might result in damages too obscure and difficult of proof for estimate other than by liquidated damages holding that language of contract did not limit plaintiffs recovery to liquidated damages holding that liquidated damages under the adea are intended to punish and deter while contrasting them to the legislative purpose of liquidated damages under the fsla