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Motion for Summary Judgment Statutory Interpretation Contract Terms

Freiberger Haber LLP

Settlement Term Sheet Constitutes Instrument for the Payment of Money Only

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Pursuant to CPLR 3213, a plaintiff may commence an action “based upon an instrument for the payment of money only or upon any judgment” by filing a summons and motion for summary judgment in lieu of complaint. The statute...more

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Plaintiff’s Allegations and Records Show Its Claim Was Time Barred

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In Southgate Owners Corp. v. Esposito, 2025 N.Y. Slip Op. 32750(U) (Sup. Ct., N.Y. County July 24, 2025) (here), plaintiff sued defendant, a shareholder in its cooperative building, seeking a declaratory judgment that 80...more

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