Since the requirement to disclose all material and necessary evidence is to be liberally construed (Allen v Crowell-Collier Publ. Co., 21 N.Y.2d 403, 407), the IAS Court properly ordered disclosure of the records. Prior criminal conduct relied upon to establish foreseeability is not limited to "the exact location where plaintiff was harmed or that it be of the same type of criminal conduct to which plaintiff was subjected" (Jacqueline S. v City of New York, 81 N.Y.2d 288, 294). The request for reports or records of assaultive and violent criminal conduct at defendant's branches located in Manhattan for a three year period prior to the occurrence herein is not overly broad or unduly burdensome since these records are kept in one central location. Likewise, it was not improper to compel a knowledgeable person from this record-keeping department to appear for an examination before trial.
Concur — Ellerin, J.P., Ross, Rubin, Nardelli and Williams, JJ.