CPLR 3213 provides an expedited path to judgment on an “instrument for the payment of money only,” but disputes often arise when a promissory note grows out of a broader contractual relationship. Two questions then become critical: whether the note contains a standalone, unconditional obligation to pay, and whether defenses based on the underlying agreement defeat summary enforcement. A related issue arises when the maker characterizes the other party’s alleged nonperformance

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.