A movant for a default judgment must submit proof of service of the summons and complaint, proof of the facts constituting the claim, and proof of the defendant's failure to answer or appear. In order to defeat the motion, the defendant must show either that there was no default, or that it has a reasonable excuse for its delay and a potentially meritorious defense.
Deutsche Bank Natl. Trust Co. v. Pezzola, NY Slip Op 06339 (2d Dep't November 17, 2021)
