Click on this link and just read. (You have to put it together bc the link won't post in the comments here) https:// www. rcfp. org/ privilege-compendium /ohio/ E. Confidential and/or nonconfidential information The constitutional protection has been held to cover non-published/non-broadcast information (e.g., reporters' notes, drafts, outtakes) even if no confidential source is involved. See e.g., Fawley v. Quirk, 9th Dist. Summit No. 11822, 1985 WL 11006, 11 Med.L.Rptr. 2336 (July 17, 1985); State v. Hamilton, Montgomery C.P. No. 85-CR-2418, 12 Med.L.Rptr. 2135 (May 6, 1986); Slagle v. Coca Cola, 30 Ohio Misc.2d 34, 507 N.E.2d 794 (Montgomery County C.P. 1986). COMPARE F. Published and/or non-published material The constitutional protection has been held to cover non-published/non-broadcast information (e.g., reporters' notes, drafts, outtakes) even if no confidential source is involved. See e.g., Fawley v. Quirk, 9th Dist. Summit No. 11822, 1985 WL 11006, 11 Med.L.Rptr. 2336 (July 17, 1985); State v. Hamilton, Montgomery C.P. No. 85-CR-2418, 12 Med.L.Rptr. 2135 (May 6, 1986). In a wrongful death action, a newspaper and photographer moved to quash subpoenas to produce unpublished photographs taken of an accident scene. The court granted the motion stating that the qualified privilege applies to unpublished news photographs and offers more protection in civil cases. Slagle v. Coca Cola, 30 Ohio Misc.2d 34, 507 N.E.2d 794 (Montgomery County C.P. 1986). The plaintiff moved to compel disclosure of outtakes and reporters' notes in a defamation action against a news station for broadcasting the arrest of plaintiff for drunk driving after which plaintiff was never charged. After in camera review of the material, the trial court granted plaintiff's motion to compel disclosure. The court of appeals declined to rule on the constitutional issues, finding that the determination of whether a qualified privilege existed depended upon a balancing of interests lying within the discretion of the trial court. Since no transcript existed of the in camera review, the court refused to find an abuse of discretion in the trial court's order to compel production of the material. Schreiber v. Multimedia of Ohio, Inc., 41 Ohio App. 3d 257, 535 N.E.2d 357 (1st Dist. 1987). ... https://www.youtube.com/watch?v=ESIzBeIcrmw

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