In Red Tulip, LLC v. Neiva, 44 AD3d 204, 209, 842 N.Y.S.2d 1 [1st Dept. 2007] a developer defaulted on a loan intended to fund the purchase and development of a vacant loft. The borrowers signed an unconditional guaranty which "absolutely, unconditionally and irrevocably" waived their right to assert defenses and counterclaims. (Id. at 206.) In Red Tulip, defaulting borrowers subsequently asserted counterclaims in opposition to the foreclosure action which alleged, among other things, that the lender prevented them from satisfying the mortgage, triggering a default. Citing to Citibank v. Plapinger, 66 NY2d 90, 92 [1985], in support of the proposition that a defense alleging fraudulent inducement of a guaranty was barred by the express terms of the guaranty where defenses were unconditionally waived, the court ultimately held that "The language of the guaranty in this case is not only as broad and unconditional as that in Citibank . . . but it also expressly waives all defenses and counterclaims . . . accordingly, we find that all . . . defenses and counterclaims . . . are barred by the guaranty." (Red Tulip at 209-210).