Practice point: Service pursuant to CPLR 308(2) is not complete until 10 days
after the filing of the affidavit of service. CPLR 320 provides that
when service is made pursuant to CPLR 308(2), the defendant has 30 days
from the time service is complete to answer the complaint.
Case: Watson v. City of New York, NY Slip Op 00245 (1st Dep't January 16, 2018)
Here is the decision.
