A plaintiff seeking leave to enter a default judgment must file proof of (1) service of a copy of the summons and complaint; (2) the facts constituting the claim; and (3) the defendant's default. In order to defeat a facially sufficient motion, the defendant must show either that there was no default, or that there is a reasonable excuse for the delay and a potentially meritorious defense.
Citimortgage, Inc. v. Weaver, NY Slip Op 04903 (2d Dep't September 1, 2021)
Tomorrow's issue: Appellate practice.
