In re Investors & Lenders Ltd., et al 156 B.R. 145 (Bankr.D.N.J. 1993)
"... a security interest in instruments can be perfected only by the secured party's taking possession. N.J.S.A. 12A: 9-304(1). Therefore, a security interest in a promissory note can only be perfected by taking possession of the note."


In re Kennedy Mortgage Co. 17 B.R.957 (Bankr.D.N.J. 1982)
Defendants have a common law right to demand production of the alleged "note" prior to making any payment on a note. "A promissory note is an "instrument" as defined by the Uniform Commercial Code. N.J.S.A. 12A:9-105 (1) (g) and 12A:3-104(2)(d)