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NOTICE OF ELECTRONIC FILING. Notice Of Commencement Of Action Subject To Mandatory Electronic Filing Form.This is a New York form and can be use in Supreme Court Statewide. In a mandatory e-filed action, the commencing party must serve the Notice of Commencement of Action Subject to Mandatory Electronic Filing (Form EFM - 1). Electronic Filing Is Now Mandatory When Commencing An Action In The Commercial Division. By Sheppard Mullin on June 8, 2010. Instant access to fillable Microsoft Word or PDF forms. Minimize the risk of using outdated forms and eliminate rejected fillings. Documents required to be filed with the Court must be filed electronically. An Affidavit of Service of the commencement papers is still required to be filed after service is complete.