Plaintiff leased its garage to defendant and now seeks discovery of the latter's records concerning the maintenance and operation of the facility, including complaints received from others in relation thereto, in a proceeding to evict this tenant and have it account for unpaid rents. Defendant sought and obtained a protective order from disclosing such information, claiming it was not "material and necessary" (cf. CPLR 3101, subd. [a]). Despite the liberality of construction...
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