A defendant who has been served with a summons other than by personal delivery may be allowed to defend the action within one year after he has knowledge of entry of a judgment against him. He must demonstrate that he did not personally receive notice of the summons in time to defend and that he has a potentially meritorious defense.
Beltran v. New York City Hous. Auth., NY Slip Op 04003 (2d Dep't June 22, 2022)