Order unanimously affirmed, with costs.
Memorandum:
Full disclosure of all material and necessary evidence is the broad rule posited by CPLR 3101 (subd [a]). Among the limited exceptions is the one at issue here, i.e., the qualified immunity granted material prepared for litigation (CPLR 3101, subd [d]). The record reveals that the material sought to be discovered was an "incident report" made during the course of plaintiff's surgery and submitted by a nurse...
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