Shram v. Masadeh

Citations

• 2024 Ohio 1662

Syllabus

DISCOVERY – ATTORNEY-CLIENT PRIVILEGE – MOTION TO COMPEL – FINAL ORDER – R.C. 2505.02(B)(4): Where defendant, a managing member of one company and a 50-percent member of another company, did not meet his burden of establishing that he was asserting the attorney-client privilege in the best interests of the companies rather than on his own behalf, the trial court did not err in granting a motion to compel documents that defendant alleged were privileged. Where a trial court's interlocutory order concerning discovery of a privileged matter is a final order pursuant to R.C. 2505.02(B)(4), an appellate court's review is limited to matters concerning the discovery of privileged material.