A plaintiff moving for leave to enter a default judgment against a defendant 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 a facially sufficient CPLR 3215 motion, a defendant must show either that there was no default, or that there is a reasonable excuse for the default and a potentially meritorious defense.
Bank of N.Y. v. DeJohn, NY Slip Op (2d Dep't July 13, 2022)
