The First Department vacated a compliance conference order directing defendants to provide plaintiff with all documents of similar incidents for the three years prior to the accident at issue, in Daniels v. Fairfield Presidential Mgt. Corp., which was decided on August 7, 2007. The court said that the directive was overly broad, and that the requested documents were neither material nor necessary to the prosecution of the action. "Discovery of evidence of prior similar accidents, while material in cases where a defect is alleged in the design or creation of a product or structure, is irrelevant and inappropriate in cases such as this, where no inherent defect is alleged."