Does attorney work-product privilege apply to the litigation for which the documents were prepared?

"New York", United States of America

The following excerpt is from Orange & Rockland Utils., Inc. v. Assessor of Town of Haverstraw Board of Review of Town of Haverstraw, 2004 NY Slip Op 51303(U) (NY 10/21/2004), 2004 NY Slip Op 51303(U) (N.Y. 2004):

In addition, the protection from disclosure provided by the attorney work-product privilege extends both to the litigation for which the materials were prepared and to any subsequent actions. [see Beascock v. Dioguardi Enterprises, Inc., 117 AD2d 1016, 499 N.Y.S.2d

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