The subject e-mail was sent after commencement of the action by a former employee of plaintiff to plaintiff's attorney at plaintiff's request following a chance encounter between the former employee and a principal of plaintiff, and recounts the former employee's recollections of conversations with plaintiff's principal and one of the defendants. After an in camera review, we find that the e-mail was not prepared for purposes of the litigation (CPLR 3101 [d] [2]), is not...
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