Practice point: A clerk does not have authority to enter a clerk's
judgment against a defendant pursuant CPLR 3215(a) if the plaintiff's
causes of action are not for a sum certain.
Case: Primary Care Ambulance Corp. v. Simpson, NY Slip Op 01898 (2d Dep't March 15, 2017)
Here is the decision.
Tomorrow's issue: Snow, ice, and an out-of-possession landlord's liability.