On December 27, 2023, the Second Department issued a decision in Deutsche Bank Natl. Trust Co. v. Mangi, 2023 NY Slip Op. 06725, noting the distinction between a person’s last known address and last known residence, explaining:
[T]he Supreme Court properly determined, in any event, that the plaintiff established that it had complied with the statute. RPAPL 1304(2) requires that the notice be sent by registered or certified mail, and also by first-class mail, to the last known address of the borrower. Contrary to the defendants’ contention, the plaintiff established that it mailed the notice to Mangi’s last known address. Although the defendants submitted evidence that Mangi was served with the summons and complaint in this action at a different address, and that the judgment dismissing a prior foreclosure action also listed a different address for Mangi, the last known address of a party is not necessarily the last known residence of that party.
(Internal quotations and citations omitted).