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.

When a borrower borrows money from a lender the repayment obligation is evidenced by a promissory note signed by the borrower and delivered to the lender.