In Malek v. Feigenbaum, the US Court of Appeals for the Second Circuit held that a post-judgment motion must be timely filed to toll notice of appeal deadlines. The court also held that FRAP 4(a)(4), which governs the effect of post-judgment motions on appeal, is a mandatory claims-processing rule subject to waiver and forfeiture, but not to equitable tolling or harmless error analysis.
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Untimely Post-Judgment Motion Does Not Toll Notice of Appeal Deadlines and is Not Subject to Equitable Exceptions: Second Circuit
