A plaintiff seeking leave to enter a default judgment must file proof of: (1) service of a copy or copies of the summons and the 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 it had a reasonable excuse for its delay and a potentially meritorious defense.
U.S. Bank N.A. v. Crockett, NY Slip Op 00211 (2d Dep't January 12, 2022)
