In Grant v. Senkowski, 95 NY2d 605 [2001] the pro se petitioner, a prison inmate, argued that his Article 78 proceeding was timely commenced because he delivered his proposed order to show cause, verified petition and request for poor person relief to prison authorities before the statute of limitations expired. The Court rejected his argument, explaining: "We recognize the greater impediments pro se prisoners may face over most other litigants in filing their legal papers on time. But, absent any evidence that the Legislature intended to vary for their benefit the filing-by-receipt requirement established in CPLR 304, we cannot depart from the statutorily mandated filing requirements by incorporating a pro se prisoner mailbox exception." (id. at 609 )