In Kandov v. Gondal, 11 A.D.3d 516, 783 N.Y.S.2d 57 [1st Dept. 2004], the Court held that the defendant was estopped from raising a claim of defective service because he failed to apprise the Department of Motor vehicles of his current address.

In Kandov, supra., the excuse proffered by the defendant for his default was that on the date of service he no longer resided at the address where service was made, which was the same address that was listed with the DMV.