DeeAnn was fiddling with the radio dial in her van and accidentally blew through a red light controlling an intersection. As a result, she clipped the rear corner of Patricio's beautiful, new sedan, causing damage to a taillight and other cosmetic body damage. The drivers stopped and exchanged insurance information, but Patricio found out after the fact that DeeAnn gave him false information. Patricio's insurance company located DeeAnn and served her with a lawsuit, filed in Texas state court, to recover the costs of repairing Patricio's car. DeeAnn was served in person at her home.

The deadline for DeeAnn to answer the lawsuit came and went, and she never filed anything with the court or made any appearance in court. Patricio's insurance company wishes to move for a default judgment against DeeAnn.

What must the insurance company do in order to successfully move for a default judgment and recover the damages they are seeking?