In Alberto Coronado v. Veolia North America Inc. & Subsidiaries et al, NY Sup. Ct. NY Cty. 450319/2019 (April 6, 2021), a motor vehicle accident case, the court held that the defendant was not entitled to obtain discovery of so-called “litigation funding” material from the plaintiff. Despite the liberal construction courts give to the CPLR’s general discovery provision, CPLR 3101(a), it held that since “the litigation funding in question is not the subject of plaintiff’s claim for damages, and is not a collateral source” within the meaning of CPLR 4545, defendants were not entitled to this discovery.