🔑 Discovery of Tax Returns In New York Under CPLR § 3101

CPLR 3101 establishes a broad rule of disclosure in New York civil practice. As a general matter, parties are entitled to full disclosure of material and necessary information relevant to the prosecution or defense of an action. Tax returns fall within that broad universe of potentially discoverable financial information.

At the same time, tax returns are not privileged under CPLR 3101(b) and are not categorically exempt from disclosure. When courts restrict access to tax returns, they are not applying a privilege and are not enforcing a statutory prohibition. Instead, New York courts apply a heightened threshold before ordering disclosure of tax returns.