In New York Schools Insurance Reciprocal v. Milburn Sales Co., Inc., 963 N.Y.S. 2d 152, 105 A.D.3d 716 (2nd Dep’t 2013), the New York Appellate Division, Second Department, narrowed the protection afforded by the work-product doctrine to investigations performed by independently retained experts. The Second Department reversed the trial court’s decision and held that work...