In order to avoid dismissal, plaintiff was required to demonstrate both a justifiable excuse for the failure to respond to the demands and a meritorious cause of action ( see, CPLR 3216 [e]). Plaintiff failed to provide a reasonable excuse for her inactivity during the four years since the commencement of the action ( see, Terry v Southern Container, 214 AD2d 983; Richter v Dunlap, 214 AD2d 983, 984). The affidavit of plaintiffs counsel, containing conclusory statements concerning the complexity of the case, does not demonstrate a reasonable excuse for the delay.

To defeat the motion, plaintiff had to show a justifiable excuse for failure to file a note of issue within the 90-day period and a good and meritorious cause of action (see, CPLR 3216 [e]; Papadopoulas v R.B. Supply Corp., 152 A.D.2d 552, 553; Highlands Ins. Co. v Maddena Constr. Co., 109 A.D.2d 1071, 1072). Plaintiff failed to make the required showing (see, Richter v Dunlap, 214 A.D.2d 983 [decided herewith]). Because five years had elapsed between commencement of the action and service of the 90-day demand, and because plaintiff's counsel acknowledged her inaction after receipt of that demand, we conclude that plaintiff's assertion of law office failure does not constitute a justifiable excuse (see, e.g., Nichols v Agents Serv. Corp., 133 A.D.2d 912, 914).