Trial Court's Discovery Order Not Final and Appealable
In Dispatch Printing Co. v. Recovery L.P, 166 Ohio App. 3d 118, 2006 Ohio 1347, 849 N.E.2d 297, the Tenth Appellate District held that a trial court's discovery order was not final and appealable because it did not "provide for unfettered discovery coupled with the danger of being unable to 'ring the proverbial bell.'" Id. at P9. the court concluded that the entry "merely provided guidance to the parties as to how discovery would proceed." Id at P10.
Central to the court's analysis was the fact that "safeguards" were in place to address the parties' concerns regarding proprietary information or trade secrets. Id at PP12-13.
Thus, the Tenth Appellate District felt confident that the trial court would undertake the necessary steps to protect the dissemination of proprietary materials and trade secrets in that case, including "additional hearings, in-camera inspections, and the like." Id. at 13.