In Kandel v. Tocher (22 AD2d 513, 256 N.Y.S.2d 898 [1st Dept 1965]), the Court held that since, by definition, the very purpose of liability insurance "is simply litigation insurance," just about everything the insurer and its employees do with respect to securing accident reports and related documents is "in contemplation and in preparation for eventual litigation" (supra, at 515). In Silberberg v. Hotpoint Division of General Electric Co. (23 AD2d 754, 259 N.Y.S.2d 60 [1st Dept 1965]), the court ordered defendant to inspect a defective washing machine, and pursuant to that order defendant had an engineer inspect the machine and plaintiff demanded the engineer's report. the court held "that this report prepared for litigation, is too clear for discussion."