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Summary Judgment Sought Even Though Summary Judgment in Lieu of Complaint at Plaintiff’s Disposal
New York’s CPLR 3213 allows a plaintiff to seek summary judgment in lieu of a complaint when liability for a sum certain is evident from an instrument for the payment of money only, such as a promissory note or unconditional guaranty. This expedited procedure avoids delays inherent in filing and answering a complaint.

Jeffrey Haber
Dec 31, 20256 min read
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