King v 105-02 Forest Hills, LLC

The best way to serve process on Corp or LLC, is to serve the Secretary of State pursuant to the BCL or LLC Law. However, the Secretary of State has been taking MONTHS to mail out pleadings to Defendants, and by the time process is received, the time to answer has often already expired. This Second Department case finds that such a delay can satisfy the "excusable default" prong.

https://www.nycourts.gov/reporter/3dseries/2024/2024_06565.htm