In order to vacate a default judgment, the movant must establish both a reasonable excuse for its default and a meritorious defense to the plaintiff's claims. A corporate defendant's failure to update the aaddress of its agent for service of process is not a reasonable excuse for defaulting. In the absence of a reasonable excuse, the issue of the defendant's defenses will not be addressed.
Shabtai v. HFZ Capital Group, LLC, NY Slip Op 05109 (1st Dep't October 10, 2023)