An attorney's work product is absolutely privileged, and is not obtainable. The privilege extends only to documents prepared by counsel acting as such, and to materials uniquely the product of a lawyer's learning and professional skills, such as those reflecting the attorney's legal research, analysis, conclusions, legal theory, or strategy.
Venture v. Preferred Mut. Ins. Co., NY Slip Op 00834 (1st Dep't February 4, 2020)
Here is the decision.
