A plaintiff seeking leave to enter a default judgment under CPLR 3215 must file proof of: (1) service of the summons and complaint; (2) the facts constituting the claim; and (3) the defendant's default. In order to defeat a facially sufficient CPLR 3215 motion, the defendant must show either that there was no default or that it had a reasonable excuse for its delay and a potentially meritorious defense.
Austin 26 Dental Group, PLLC v. Sino Northeast Metals (U.S.A.), Inc., NY Slip Op 04187 (2d Dep't August 14, 2024)