has "a mere obligation to pay money," as opposed to "specific, tangible funds of which claimant was the owner and entitled to immediate possession." Ehrlich v. Howe, 848 F. Supp. 482, 492 (S.D.N.Y. 1994); Selinger Enters., Inc. v. Cassuto, 860 N.Y.S.2d 533, 536 (App. Div.) ("mere right to payment cannot be the