N.Y. Crim. Proc. Law § 245.65

§ 245.65 Work product.\n This article does not authorize discovery by a party of those portions\nof records, reports, correspondence, memoranda, or internal documents of\nthe adverse party which are only the legal research, opinions, theories\nor conclusions of the adverse party or its attorney or the attorney's\nagents, or of statements of a defendant, written or recorded or\nsummarized in any writing or recording, made to the attorney for the\ndefendant or the attorney's agents.\n