HSBC Bank USA, N.A. v. Saris

2025 NY Slip Op 07287
CourtAppellate Division of the Supreme Court of the State of New York
DecidedDecember 24, 2025
DocketIndex No. 66026/14
StatusPublished
AuthorDuffy
Cited by1 cases

This text of 2025 NY Slip Op 07287 (HSBC Bank USA, N.A. v. Saris) is published on Counsel Stack Legal Research, covering Appellate Division of the Supreme Court of the State of New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
HSBC Bank USA, N.A. v. Saris, 2025 NY Slip Op 07287 (N.Y. Ct. App. 2025).

Opinion

HSBC Bank USA, N.A. v Saris (2025 NY Slip Op 07287)
HSBC Bank USA, N.A. v Saris
2025 NY Slip Op 07287
Decided on December 24, 2025
Appellate Division, Second Department
Duffy, J.P.
Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431.
This opinion is uncorrected and subject to revision before publication in the Official Reports.


Decided on December 24, 2025 SUPREME COURT OF THE STATE OF NEW YORK Appellate Division, Second Judicial Department
COLLEEN D. DUFFY, J.P.
ROBERT J. MILLER
HELEN VOUTSINAS
PHILLIP HOM, JJ.

2022-07584
(Index No. 66026/14)

[*1]HSBC Bank USA, National Association, etc., respondent,

v

Emanuel F. Saris, et al., appellants.


APPEAL by the defendants, in an action to foreclose a mortgage, from an order of the Supreme Court (Joseph A. Santorelli, J.), dated August 11, 2022, and entered in Suffolk County. The order, insofar as appealed from, denied those branches of the defendants' motion which were pursuant to CPLR 5015(a)(1) and (4) to vacate so much of an order of the same court dated October 23, 2015, as granted those branches of the plaintiff's unopposed motion which were for leave to enter a default judgment against the defendants and for an order of reference, and an order and judgment of foreclosure and sale (one paper) of the same court entered August 22, 2016.



Charles Wallshein, Melville, NY, for appellants.

Reed Smith LLP, New York, NY (James N. Faller and Andrew B. Messite of counsel), for respondent.



DUFFY, J.P.

OPINION & ORDER

The issue on appeal, an issue of first impression for this Court, is whether a party's attendance at a mandatory settlement conference pursuant to CPLR 3408 constitutes an appearance by a party for the purpose of CPLR 3215(g), which provides, among other things, that a party who has appeared in an action is entitled to at least five days' notice of an application for leave to enter a default judgment. The defendants appeal from an order dated August 11, 2022 (hereinafter the August 2022 order), which, inter alia, denied those branches of the defendants' motion which were pursuant to CPLR 5015(a)(1) and (4) to vacate so much of an order dated October 23, 2015 (hereinafter the October 2015 order), as granted those branches of the plaintiff's unopposed motion which were for leave to enter a default judgment against the defendants and for an order of reference, and an order and judgment of foreclosure and sale entered August 22, 2016. The defendants contend, among other things, that their attendance at a mandatory settlement conference in the action on March 6, 2015 (hereinafter the March 2015 conference), constituted an appearance for the purpose of the notice provisions under CPLR 3215(g) and that, since they were not given the requisite five days' notice of the plaintiff's motion, inter alia, for leave to enter a default judgment against them, reversal is warranted. For the reasons set forth below, we affirm the August 2022 order insofar as appealed from on the ground, among others, that the Supreme Court properly determined that the defendants had not appeared in the action and, thus, the five-day notice provision set forth in CPLR 3215(g) was not applicable with respect to the plaintiff's motion, inter alia, for leave to enter a default judgment against the defendants.

I. Background of the Action

In July 2014, the plaintiff commenced this action against the defendants to foreclose a mortgage encumbering certain real property located in Suffolk County (hereinafter the premises) and owned by the defendants. Subsequently, the Supreme Court held the March 2015 conference pursuant to CPLR 3408. The defendants contend, and the court noted in the October 2015 order, that [*2]they attended the March 2015 conference. However, the defendants did not file a notice of appearance, interpose an answer, or make any motion at that time. Thereafter, the plaintiff moved, inter alia, pursuant to CPLR 3215 for leave to enter a default judgment against the defendants and for an order of reference. The defendants did not oppose. In the October 2015 order, the court, among other things, granted the plaintiff's motion. Thereafter, the court issued an order and judgment of foreclosure and sale, entered August 22, 2016, inter alia, directing the sale of the premises.

In May 2017, the defendant Emanuel F. Saris moved, pro se, inter alia, to temporarily stay the foreclosure sale and auction (hereinafter the May 2017 motion). In an order dated November 15, 2017, the Supreme Court denied the May 2017 motion. The premises were then sold to the plaintiff in May 2019.

In February 2020, the defendants moved, among other things, pursuant to CPLR 5015(a)(1) and (4) to vacate so much of the October 2015 order as granted those branches of the plaintiff's unopposed motion which were for leave to enter a default judgment against the defendants and for an order of reference, and the order and judgment of foreclosure and sale. Both defendants averred in support of their motion that they attended the March 2015 conference, and annexed a copy of the October 2015 order to their motion papers. The plaintiff opposed. In the August 2022 order, the Supreme Court, inter alia, denied those branches of the defendants' motion. The defendants appeal.

II. The Relevant Law

A. Defaulting Defendants

"A 'defendant in default is not entitled to affirmative relief of a non-jurisdictional nature absent vacatur[ ] of his or her default'" (US Bank N.A. v Scaffidi, 238 AD3d 1092, 1093, quoting Bank of N.Y. Mellon v Lawson, 176 AD3d 1155, 1157).

B. CPLR 5015(a)(1)

"A party seeking to vacate an order or judgment entered upon his or her default in opposing a motion must demonstrate both a reasonable excuse for the default and a potentially meritorious opposition to the motion" (CitiMortgage, Inc. v Ramlal, 238 AD3d 976, 977). "'Although a motion to vacate an order on the ground of excusable default must be made within one year after service of a copy of the order with written notice of entry upon the moving party (see CPLR 5015[a][1]), the Supreme Court has the inherent authority to vacate an order in the interest of justice, even where the statutory one-year period under CPLR 5015(a)(1) has expired'" (HSBC Bank USA, N.A. v Gallo, 238 AD3d 1123, 1125, quoting JPMorgan Chase Bank, N.A. v Baptiste, 188 AD3d 848, 850).

C. CPLR 5015(a)(4)

"'CPLR 5015(a)(4) provides for vacatur of a judgment or order upon the ground of lack of jurisdiction to render the judgment or order'" (Deutsche Bank Natl. Trust Co. v Simpson, 208 AD3d 1305, 1307 [internal quotation marks omitted], quoting Bank of N.Y. Mellon v Ziangos, 194 AD3d 778, 779). Any defendant who has appeared in an action is entitled to at least five days' notice of an application for leave to enter a default judgment (see CPLR 3215[g][1]).

"'[T]he failure to provide a defendant who has appeared in an action with the notice required by CPLR 3215(g)(1), like the failure to provide proper notice of other kinds of motions, is a jurisdictional defect that deprives the court of the authority to entertain a motion for leave to enter a default judgment'" (Flagstar Bank, FSB v Powers, 236 AD3d 864, 865-866, quoting Paulus v Christopher Vacirca, Inc.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

LaSalle Bank N.A. v. Khanom
2026 NY Slip Op 30897(U) (New York Supreme Court, Kings County, 2026)

Cite This Page — Counsel Stack

Bluebook (online)
2025 NY Slip Op 07287, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hsbc-bank-usa-na-v-saris-nyappdiv-2025.