The applicant must submit proof of service of the summons and complaint or summons and notice, proof of the facts constituting the cause of action, and proof of the defaulting defendant's failure to answer or appear, pursuant to CPLR 3215[f]. In order to demonstrate the facts constituting the cause of action, the plaintiff need only submit sufficient proof to enable a court to determine if the cause of action is viable, since defaulters are deemed to have admitted all factual allegations contained in the complaint and all reasonable inferences that flow from them.
Banks v. 110-18 198th St. Corp., NY Slip Op 03222 (2d Dep't May 18, 2022)
