2006 New York Code - Default Judgment.

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