Plaintiff's attorney provides satisfactory proof that plaintiff did not default on defendants' motion for a preclusion order, namely, his affirmation of service of papers in opposition and a cross motion for a protective order on March 3, 2001, and a receipt from his lawyers service stating that such papers were filed on March 13, 2001. Plaintiff's attorney also provides a satisfactory explanation for not having appeared in court for the oral argument that defendants assert...
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