High threshold to achieve narrow result

At least once or twice a year, a new matter will come across my desk that is not an action but rather an application for pre-action disclosure that has been served on one of my clients. This application usually takes the form of an order to show cause seeking to require one of my clients to preserve and turn over various documents and/or equipment. This application may also seek to have a specific piece of equipment or condition made available for inspection before it is modified or destroyed. CPLR…