August 1, 2020

CPLR 3215(c).

The statute provides that "[i]f the plaintiff fails to take proceedings for the entry of judgment within one year after [a] default, the court shall not enter judgment but shall dismiss the complaint as abandoned, without costs, upon its own initiative or on motion, unless sufficient cause is shown why the complaint should not be dismissed." It is not necessary that the plaintiff actually obtain a default judgment within one year of the default in order to avoid dismissal.

Bank of Am., N.A. v. Wessen, NY Slip Op 04141 (2d Dep't July 22, 2020)

Here is the decision.