The absolute privilege under CPLR 3101(c) is limited to materials prepared by an attorney, while acting as an attorney, which contain the attorney's legal analysis, conclusions, theory, or strategy. Materials or documents that could have been prepared by a layperson do not fall within the attorney work product exception.
Bent-Anderson v. Singh, NY Slip Op 05676 (2d Dep't October 12, 2022)
