An objection that the summons and complaint was not properly served is waived if, after raising the objection in a pleading, the defendant does not move for judgment on that ground within sixty days after serving the pleading, unless the court extends the time upon the ground of undue hardship, pursuant to CPLR 3211[e].
Bank of N.Y. Mellon v. Shurko, NY Slip Op 05975 (2d Dep't October 26, 2022)