N.Y. Civil Practice Law and Rules (CPLR) 320(a) provides three ways in which a defendant may appear in an action: (1) serving an answer; (2) serving a notice of appearance; or (3) making a motion which has the effect of extending the time to answer.

A motion which has the effect of extending the time to answer includes the commonplace motion to dismiss pursuant to CPLR 3211, which extends the time to answer to 10 days from service of the order deciding the motion with notice of entry. See CPLR 3211(f).