Need a reason to go to the DMV? A defendant can be served at the address on their license even if it is out of date In Perlbinder Holdings LLC v. Patel, 2022 NY Slip Op 01106 (N.Y. App. Div. 1st Dep’t February 17, 2022), the New York Appellate Division, First Department considered whether service was proper. The Court held that affidavits of service constituted prima facie evidence of proper service and that presumption was not rebutted by the defendants.Interestingly, the Court stated that because the defendant failed to notify the Department of Motor Vehicles of his change of address, as required by Vehicle and Traffic Law § 505(5), the defendant was estopped from challenging service at his former address.