No Complaint, No Problem! Navigating CPLR 3213

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A CPLR 3213 motion is a procedural mechanism in New York that allows a party to make a motion for summary judgment before even filing a complaint in actions based upon “an instrument for the payment of money only or a judgment.” A motion for summary judgment in lieu of a complaint, as the CPLR 3213 motion is often referred, provides a quick avenue for relief, melding pleadings and motion practice into one step for claims that are so presumptively meritorious that a formal complaint is superfluous. Practitioners must be mindful, however, of the motion’s strict procedural requirements. 

This program will provide an overview of the procedural requirements for a 3213 motion, as well as “best practices” for effectively utilizing the motion in order to secure an expedited remedy for a commercial transaction gone awry.

 

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