Speece v. Speece, 2018 Ohio 4081

Marcia and Bryan Speece were involved in ongoing divorce proceedings in Geauga C.P. No. 2015 DC 00460.
On June 6, 2018 the trial court ordered a stay of discovery into the financial records of Janet and Peter Speece while it considered appointing a Special Master to review those records in camera.
On August 9, 2018 the trial court vacated the June 6 stay and ordered that Janet be added as a defendant; Marcia was granted leave to amend her complaint to name Janet.
Janet (appellant) timely appealed the August 9 order and sought stays from the trial court and this court to block discovery of her financial records; the trial court denied her stay request.
Janet argued her financial records were confidential and claimed the vacation of the stay was immediately appealable; Marcia opposed emergency relief and sought discovery.
The appellate court considered whether the August 9 judgment was a final, appealable order and whether any narrow exception to interlocutory discovery orders applied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the August 9, 2018 order (adding Janet as a party and vacating the stay of discovery) is a final, appealable order	Janet: order is reviewable because it permits discovery into her confidential financial records	Marcia: order merely adds a party and lifts a stay; not a final appealable decision	Court: Not final or appealable; appeal dismissed for lack of jurisdiction
Whether the discovery-order exception for compelled production of privileged documents applies	Janet: her records are confidential/privileged because she was not previously a party	Marcia: no privilege shown; trial court may use protective measures; no compelled production was ordered	Court: Exception does not apply—trial court did not compel production of privileged documents and privilege was not established

Gen. Acc. Ins. Co. v. Ins. Co. of N. Am., 44 Ohio St.3d 17 (1989) (if an order is not final, appellate court lacks jurisdiction)
State ex rel. Steckman v. Jackson, 70 Ohio St.3d 420 (1994) (discovery orders are interlocutory and generally not appealable)