CPLR 3215(c) directs that "[i]f the plaintiff fails to take proceedings for the entry of judgment within one year after the default, the court shall not enter judgment but shall dismiss the complaint as abandoned, without costs, upon its own initiative . . . , unless sufficient cause is shown why the complaint should not be dismissed." However, pursuant to CPLR 3408(n), the one-year deadline is tolled while mandatory settlement conferences are pending.
Bank of Am., N.A. v. Keefer, NY Slip Op 00231 (2d Dep't January 21, 2026)
