Practice point: A party's time to move to renew or reargue an order pursuant to CPLR 2221 does not begin to run until it is served with notice of entry of the order.
Students should note that where an order affects a party's rights, the successful moving party must serve it on the adverse party.
Case: Garcia v. City of New York , NY Slip Op 03033 (1st Dept. 2010 )