No Proof of Service of Notice of Entry of Default Judgment; One Year Deadline Never Triggered
The First Department noted that the one-year deadline for a motion to vacate a default judgment (CPLR 5015) was never triggered because the record included no proof that the notice of entry of the default judgment was served. Gottlieb v Northriver Trading Co, LLC, 2013 NY Slip Op 03618, 1st Dept, 5-21-13
