New York Consolidated Laws, Criminal Procedure Law - CPL § 240.10 Discovery;  definition of terms

1. “Demand to produce” means a written notice served by and on a party to a criminal action, without leave of the court, demanding to inspect property pursuant to this article and giving reasonable notice of the time at which the demanding party wishes to inspect the property designated.

2. “Attorneys' work product” means property to the extent that it contains the opinions, theories or conclusions of the prosecutor, defense counsel or members of their legal staffs.

3. “Property” means any existing tangible personal or real property, including, but not limited to, books, records, reports, memoranda, papers, photographs, tapes or other electronic recordings, articles of clothing, fingerprints, blood samples, fingernail scrapings or handwriting specimens, but excluding attorneys' work product.

4. “At the trial” means as part of the people's or the defendant's direct case.