ORDER & OPINION GRANTING SUMMARY JUDGMENT AND EVIDENTIARY PRECLUSION In September 2018, Plaintiff brought the instant action against Defendant to recover payments outstanding under a promissory note. See Am. Compl. (ECF No. 11). Plaintiff now moves for summary judgment under Rule 56 of the Federal Rules of Civil Procedure and for an evidentiary preclusion order pursuant to Rule 37 of the Federal Rules of Civil Procedure. See ECF No. 45. For the reasons discussed below, Plaintiff’s motion for summary judgment and Rule 37 sanctions is granted. BACKGROUND Plaintiff Mail America (“Plaintiff”) began to perform services for Defendant World Healing Center Church (“Defendant”) in early 2006, including printing and distributing periodic mailers to Defendant donors. See Opp’n Br. (ECF No. 52), at 6. For nearly 15 years, Defendant had been falling behind its payment obligations, with over $5.6 million in arrears by early 2012. See id. To consolidate all outstanding balances, on April 26, 2012, Defendant executed and delivered to Plaintiff a promissory note in the principal amount of $5,621,851.62 (the “Promissory Note”). See Am. Compl., at 8. As a result of Defendant’s default on its payment obligations under the Promissory Note, the parties entered into a forbearance agreement in December 2014 (the “2014 Forbearance Agreement”). See Resp. Statement (ECF No. 51), at 20. In the 2014 Forbearance Agreement, Defendant acknowledged the validity of the Note and its default thereunder. See Statement of Undisputed Facts (ECF No. 45, Ex. A) (“SOF”), at 22-27. In October 2017, Defendant defaulted on its obligations under the 2014 Forbearance Agreement by failing to make any further payments to Plaintiff. See id. at 12. Plaintiff continued to forbear from enforcing its rights under the Promissory Note and engaged in discussions with Defendant regarding a new forbearance agreement. See SOF, at 32. On July 19, 2018, the parties executed another forbearance agreement (the “2018 Forbearance Agreement”). See id. at 38-45. In the 2018 Forbearance Agreement and a related affidavit (the “2018 Affidavit”), Defendant acknowledged that its outstanding obligation to Plaintiff under the Promissory Note totaled $3,098,380.06, as of June 30, 2018. See Nation Decl. (ECF No. 46), Ex. 4. After Defendant again defaulted on its payment obligations under the 2018 Forbearance Agreement, on September 7, 2018, Plaintiff notified Defendant in writing that it elected to accelerate payment of all outstanding sums due under the Promissory Note and demanded that Defendant pay such accelerated sums by September 17, 2018. See SOF, at
