The sheriff shall file with the clerk a return within twenty days after he has delivered a chattel; it shall include all papers delivered to or served on him and a statement of all action taken by him. Where the sheriff has not filed a return before the hearing of a motion made by any party to punish him for contempt for such failure, he may be punished for contempt. At least ten days' notice of such motion shall be given to the sheriff.
New York Legal Code