Pursuant to CPLR 3215(c), "[i]f the plaintiff fails to take proceedings for the entry of judgment within one year after the default," the court will not enter judgment and will dismiss the complaint as abandoned. The plaintiff does not have to actually obtain a default judgment within one year, or even seek it, at least not specifically. As long as the plaintiff initiates proceedings for the entry of a judgment within one year of the default, there is no basis for dismissal of the complaint.
Deutsche Bank Natl. Trust Co. v. Khalil, NY Slip Op 04898 (2d Dep't August 10, 2022)
