On a motion to vacate a default based on intrinsic fraud, that is, on the basis that the allegations in the complaint are false, the defendant must establish both a reasonable excuse for the default and a potentially meritorious defense to the action.
JPMorgan Chase Bank, N.A. v. Multani, NY Slip Op 04346 (2d Dep't July 14, 2021)
Tomorrow's issue: A claim for fraudulent misrepresentation.