While compelling disclosure of tax returns is generally disfavored, the motion may be granted where, as here, the defendant demonstrates both that the specific information ordered disclosed is necessary to defend the action, and unavailable from other sources. Prior to granting the motion, the court inspected the tax returns in camera and deemed them relevant. Further, the redactions of those filings directed by the court's order ensures that discovery is narrowly tailored to the issues in controversy. Finally, the court's order does not constitute inappropriate judicial pruning, since the defendant's demand is not overbroad or burdensome, and it does not seek irrelevant material or conclusions. To the extent that plaintiffs are concerned about the use of the returns for purposes unrelated to the action, they may seek an appropriate protective order.
Currid v. Valea, NY Slip Op 03590 (1st Dep't June 25, 2020)
Here is the decision.
