February 24, 2022

CPLR 3215(c).

"If 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."  In order to establish sufficient cause within the meaning of the statute, the party opposing dismissal must demonstrate that it had a reasonable excuse for the delay in taking proceedings for entry of a default judgment and that it has a potentially meritorious action.

Bank of N.Y. Mellon Trust Co. v. Kyung Soon Lee, NY Slip Op 00996 (2d Dep't February 16, 2022)

Here is the decision.