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Litigants suing under a note or guaranty want one thing—their money, and they want it quickly. CPLR 3213 provides the vehicle for such litigants to reach a speedy judgment. Pursuant to CPLR 3213 a party may commence an action by serving a motion for summary judgment in lieu of complaint “when the action is based upon an instrument for the payment of money.” Thus, CPLR 3213 provides plaintiffs with a way to skip discovery and immediately seek a judgment.

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