New York Laws
Article 245 - Discovery
245.65 - Work Product.

This article does not authorize discovery by a party of those portions
of records, reports, correspondence, memoranda, or internal documents of
the adverse party which are only the legal research, opinions, theories
or conclusions of the adverse party or its attorney or the attorney's
agents, or of statements of a defendant, written or recorded or
summarized in any writing or recording, made to the attorney for the
defendant or the attorney's agents.

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