If a defendant does not answer a lawsuit he defaults. As a default litigant the defendant would be denied the right to argue the facts presented in the complaint. However, the default also acts to deny the plaintiff a jury trial. And, the defendant can still argue the plaintiff's damage amounts. Without a jury because of the default, the plaintiff's damage award, in particular punitive damages, is solely up to the presiding judge. Question: How does a plaintiff go about getting punitive damage award in a default judgment from a judge who leanings toward favoring the default defendant?