N.Y. C.P.L.R. 1203

§ 1203. Default judgment. No judgment by default may be entered\nagainst an infant or a person judicially declared to be incompetent\nunless his representative appeared in the action or twenty days have\nexpired since appointment of a guardian ad litem for him. No default\njudgment may be entered against an adult incapable of adequately\nprotecting his rights for whom a guardian ad litem has been appointed\nunless twenty days have expired since the appointment.\n