Spectrum Systems International v. Chemical Bank

OPINION OF THE COURT

Kaye, J.

In an action to recover fees for consulting services, Spectrum Systems International Corporation demanded that defendant, Chemical Bank, produce certain documents pertaining to the bank’s internal investigation of possible fraud by employees and vendors, including Spectrum. Chemical responded by seeking a protective order, asserting that the documents were protected from disclosure by the attorney-client privilege, by the attorney work product doctrine, and as material *375prepared in anticipation of litigation. This appeal requires us to consider whether a report…