A process server's affidavit of service establishes a prima facie case as to the method of service and, therefore, gives rise to a presumption of proper service. A defendant's sworn denial of receipt of service generally rebuts the presumption and necessitates an evidentiary hearing. However, no hearing is required where the defendant fails to swear to specific facts to rebut the statements in the affidavit.
Federal Natl. Mtge. Assn v. Grossman, NY Slip Op 03095 (2d Dep't May 11, 2022)
