In Palmer v. GTE California, Inc. (2003) 30 Cal.4th 1265, the California Supreme Court confirmed that "the written notice of entry of judgment served on the party who moves for a new trial need not, for the purposes of sections 659 and 660, be a separate document entitled 'notice of entry of judgment.'" (Palmer, supra, 30 Cal.4th at p. 1277.) Rather, the court reaffirmed that "no particular form of notice is required, and that in counties that do not maintain a judgment book a file-stamped copy of the judgment suffices as 'written notice' ..." for the purpose of commencing the jurisdictional time periods under these statutes. (Ibid.)