The challenge to defendant's dismissal motion for lack of standing is without merit because defendant did file an appearance (albeit late), made a demand for complaint pursuant to CPLR 3012 (b), and moved to dismiss the complaint on statute of limitations grounds before plaintiff ever served his complaint and cross-moved for a default judgment. Notwithstanding defendant's lack of an excuse for its eight-month delay in responding to the summons with notice, plaintiff failed...
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