Paul Napoli, as the proponent of the privilege, bears the burden of establishing that the information sought is immune from disclosure, which he has failed to do (see Stafford v A&E Real Estate Holdings, 192 A.D.3d 648 [1st Dept 2021]). To the extent Paul Napoli opposes specific demands, Paul Napoli shall comply with CPLR 3122(b)
The Court has previously resolved multiple discovery disputes between the parties. (Stafford v A&E Real Estate Holdings, LLC, 2020 N.Y. Slip Op. 33090[U], 1 [N.Y. Sup Ct, New York County 2020], affd, 192 A.D.3d 648, 648 [1st Dept 2021]).