New York state has long endorsed a policy of affording liberal discovery of all matters that are "material and necessary in the prosecution or defense of an action," as codified in CPLR 3101(a). See Forman v. Henkin, 30 N.Y.3d 656 (2018); Allen v. Crowell-Collier Publ. Co., 21 N.Y.2d 403 (1968). Common-law and statutory privileges that shield relevant information and evidence from discovery are anathema to that policy. They pose "an 'obstacle' to the truth-finding process… ." Ambac Assur. v. Countrywide Home Loans, 27 N.Y.3d 616 (2016), quoting Matter of Jacqueline F., 47 N.Y.2d 215 (1979). Accordingly, such privileges are supposed to be narrowly construed and applied in a manner consistent with the purposes underlying the immunity. See Forman; Ambac Assur.; Spectrum Systems Intern. v. Chemical Bank, 78 N.Y.2d 371 (1991).