1. Order of Reference – asks for appt of referee. Essential part of every motion and goal of the plaintiff to have a referee appointed to be able to calculate amount owed to the lender.
2. Motion for Summary Judgment – Filed by the plaintiff if the defendant answered and seeks to strike the defendant’s answer by showing that that there are no material issues of fact requiring a trial and no material issues of law raised by the defendant that require resolution.
3. Motion for a Default Judgment – Filed by the plaintiff if the defendant does not answer the summons and complaint. But under the CPLR this must be done within one year or the foreclosure action would get dismissed.