t. to Compel Production of Documents Subject to Improper Claim of Privilege, ECF No. 46, at 3 ("Def.'s Supp. Opp."); see also Fed. R. Civ. P. 501; Allied Irish Banks v. Bank of Am., N.A., 240 F.R.D. 96, 102 (S.D.N.Y. 2007) ("Because this Court's subject matter jurisdiction is based upon diversity . . state law provides the r