An answer to the complaint may also contain a counterclaim. A counterclaim seeks relief.The prayer for relief is the part of complaint where a plaintiff states the damages or other remedies it is seeking from the court in a lawsuit. The prayer for relief was to ask Defendant to pay for my personal hours spent on Defendant's errors. Here you would copy the same heading from the complaint except change complaint to answer. I would also request a jury trial. Generally speaking, a complaint can be amended at any time. Plaintiff will need to make a motion with the court, requesting leave to amend. You would need to obtain a Court's default judgment and submit a default packet with all of the necessary information to prove up your damages.