In General Notice of Motion Affidavit in Support Serving the Motion Affidavit of Service Filing the Motion With the Court Opposition Papers Movant should call the Court's clerk to arrange the scheduling of the emergency motion during the Court's jury trial call week.Motion for Judgment Notwithstanding the Verdict, or in the Alternative, for. (a) Default and entry. You may suggest up to three (3) preferred dates (60 to 90 days out) using the "Note to Clerk" option at the time the motion is submitted for e-filing. CPLR 3215 governs default judgments. Counsel seeking a default judgment also should be familiar with: • CPLR 2004, governing extensions of time generally. Share your videos with friends, family, and the world. In certain circumstances, defendants may obtain. I assume the other side made a motion to set aside based upon excuseable neglect, and was successful?