In re Subpoena Duces Tecum Served Upon Attorney Potts

(¶ 1} Appellant, attorney John F. Potts, appeals from the judgment of the Lucas County Court of Appeals, which affirmed the trial court’s order for an in-camera review of subpoenaed documents. For the following reasons, we (1) reverse the judgment of the court of appeals in part and hold that a trial court, in responding to a motion to quash a subpoena duces tecum seeking the production of documents before trial, must first conduct an evidentiary hearing, which may be held in camera, in order that the proponent of the subpoena can demonstrate why the subpoena is not unreasonable or…