In Phoenix Acquisition Corp. v. Campcore, Inc., 81 NY2d 138 (1993) the Court of Appeals found that the statute of limitations for an action to recover on a promissory note payable on demand accrues at the time of its execution. However, in an action to recover on a promissory note payable in installments, "separate causes of action accrued as installments of the loan indebtedness became due and payable"; thus, the statute of limitations begins to run on the date each installment becomes due and is defaulted upon, unless the debt is accelerated. (Id. at 141.)