Williams-Salmon v. Raheja

Citations

• 2022 Ohio 1675

Syllabus

Civ.R. 33 Civ.R. 34 interrogatories discovery dispute motion to compel blanket assertion of privilege Fifth Amendment right against self-incrimination Ohio Constitution, Article I, Section 10. The trial court did not err or abuse its discretion in compelling appellants' discovery response when appellants failed to properly invoke their Fifth Amendment right against self-incrimination by giving the same blanket response to 116 discovery requests. The onus was not on the trial court to perform a question-by-question inquiry as to the merits of the appellants' assertion of privilege. The appellants first had to assert the privilege in specifics sufficient upon which the trial court determines whether the privilege had been properly asserted as to each discovery request.