A Practice Note examining key issues for asserting and litigating the attorney-client privilege, trial preparation privilege, and work product doctrine in New York state court, including how to assert privilege in connection with testimony, deposition notices, document requests, subpoenas, interrogatories, requests for admissions, and pre-action and post-judgment discovery. This Note also examines privilege logs, inadvertent disclosures, challenging a privilege assertion, using referees or special masters, and appellate review.