The motion court properly exercised its discretion in requiring the production of documents responsive to the above-specified demands. Plaintiff failed to meet its burden to establish that the audit report sought by defendants was prepared primarily, if not solely, in anticipation of litigation (see Zampatori v. United Parcel Serv., 94 A.D.2d 974; Chemical Bank v. Natl. Union Fire Ins. Co., 70 A.D.2d 837). It also failed to meet its burden to identify any other responsive, putatively privileged documents (see McCarthy v. Klein, 238 A.D.2d 552).
THIS CONSTITUTES THE DECISION AND ORDER OF THE SUPREME COURT, APPELLATE DIVISION, FIRST DEPARTMENT.