CPLR 3215(c) provides that "[i]f 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 show sufficient cause, the plaintiff is required to demonstrate that it had a reasonable excuse for the delay and that it has a potentially meritorious action. Where the action is subject to a mandatory settlement conference, pursuant to CPLR 3408, the one-year deadline imposed by CPLR 3215(c) is tolled.
Citimortgage, Inc. v. Kimmerling, NY Slip Op 05246 (2d Dep't October 18, 2023)
