To be "framed" by the pleadings, an issue attacked by an affirmative defense must be either "alleged" or "referenced" in the complaint itself. See Diaz-Verson v. Walbridge Aldinger Co., 54 So. 3d 1007, 1010-11 (Fla. 2d DCA 2010). Contrary to the attorneys’ assertion, the complaint's allegations about the parties’ intent in making the agreement do not reference any intent foreign to its text.

We find that the petitioners have met their burden of proving the elements necessary for certiorari relief. Discovery is limited to those matters relevant to the litigation as framed by the parties' pleadings.Diaz–Verson v. Walbridge Aldinger Co., 54 So.3d 1007, 1011 (Fla. 2d DCA 2010); Capco Props., LLC v. Monterey Gardens of Pinecrest Condo., 982 So.2d 1211, 1213–14 (Fla. 3d DCA 2008); Richard Mulholland & Assocs. v. Polverari, 698 So.2d 1269, 1270 (Fla. 2d DCA 1997); Krypton Broad. of Jacksonville, Inc. v. MGM–Pathe Commc'ns Co., 629 So.2d 852, 854 (Fla. 1st DCA 1993), disapproved on other grounds by Allstate, 655 So.2d at 95. In the instant case, Mirmelli's complaint and Hannon's affirmative defenses do not implicate the financial records of Rousso or Alhadeff.

We find that the petitioners have met their burden of proving the elements necessary for certiorari relief. Discovery is limited to those matters relevant to the litigation as framed by the parties' pleadings.Diaz–Verson v. Walbridge Aldinger Co., 54 So.3d 1007, 1011 (Fla. 2d DCA 2010) ; Capco Props., LLC v. Monterey Gardens of Pinecrest Condo., 982 So.2d 1211, 1213–14 (Fla. 3d DCA 2008) ; Richard Mulholland & Assocs. v. Polverari, 698 So.2d 1269, 1270 (Fla. 2d DCA 1997) ; Krypton Broad. of Jacksonville, Inc. v. MGM–Pathe Commc'ns Co., 629 So.2d 852, 854 (Fla. 1st DCA 1993), disapproved on other grounds by Allstate, 655 So.2d at 95. In the instant case, Mirmelli's complaint and Hannon's affirmative defenses do not implicate the financial records of Rousso or Alhadeff.

” “Certiorari review of a discovery order is appropriate ‘when a discovery order departs from the essential requirements of law, causing material injury to a petitioner throughout the remainder of the proceedings below and effectively leaving no adequate remedy on appeal.’ ” Diaz–Verson v. Walbridge Aldinger Co., 54 So.3d 1007, 1009 (Fla. 2d DCA 2010) (quoting Allstate Ins. Co. v. Langston, 655 So.2d 91, 94 (Fla.1995)). Disclosure of information, including material protected by privilege, trade secrets, or work product, can result in irreparable harm. Diaz–Verson, 54 So.3d at 1009.

" "Certiorari review of a discovery order is appropriate 'when a discovery order departs from the essential requirements of law, causing material injury to a petitioner throughout the remainder of the proceedings below and effectively leaving no adequate remedy on appeal.' " Diaz-Verson v. Walbridge Aldinger Co., 54 So. 3d 1007, 1009 (Fla. 2d DCA 2010) (quoting Allstate Ins. Co. v. Langston, 655 So. 2d 91, 94 (Fla. 1995)). Disclosure of information, including material protected by privilege, trade secrets, or work product, can result in irreparable harm. Diaz-Verson, 54 So. 3d at 1009.

Straub v. Matte, 805 So.2d 99, 100 (Fla. 4th DCA 2002).Rappaport v. Mercantile Bank, 17 So.3d 902, 906 (Fla. 2d DCA 2009) (quotes omitted); see also Diaz-Verson v. Walbridge Aldinger Co., 54 So.3d 1007, 1009 (Fla. 2d DCA 2010) (noting that the disclosure of personal financial information may cause irreparable harm when a person is compelled to disclose it and the information is not relevant to the proceedings at issue). "A party's finances, if relevant to the disputed issues of the underlying action, are not excepted from discovery under this rule of relevancy, and courts will compel production of personal financial documents and information if shown to be relevant by the requesting party."

As to relevancy, information sought in discovery must be relevant to the issues to be litigated, as framed by the pleadings. Diaz-Verson v. Walbridge Aldinger Co. , 54 So. 3d 1007, 1011 (Fla. 2d DCA 2010). By conducting an in camera inspection, a trial court can segregate irrelevant documents from relevant documents.

Even though "[t]he disclosure of various types of information can result in irreparable harm, including material protected by privilege, trade secrets, or work product," the baseline "test for discovery is always relevance" to the disputed issues of the underlying action. Diaz-Verson v. Walbridge Aldinger Co., 54 So. 3d 1007, 1009 (Fla. 2d DCA 2010). Indeed, in American Home Assurance Co. v. Vreeland, 973 So. 2d 668, 672 (Fla. 2d DCA 2008), this court allowed discovery of an underwriting file limited to documents pertaining to a specific issue in the litigation—whether Aerolease of America was the owner or lienholder of the insured aircraft—while coverage was still in dispute.

However, a trial court's discretion is not without limitations and, thus, the relevant inquiry turns on the allegations as framed by the pleadings. Diaz–Verson v. Walbridge Aldinger Co., 54 So. 3d 1007, 1011 (Fla. 2d DCA 2010). Petitioner raises her constitutional right to privacy as a bar to the discovery of her personal financial information.

This Court concluded that we had jurisdiction because permitting the discovery constituted a departure from the essential requirements of law "and the discovery of confidential financial information is the type of 'cat out of the bag' discovery that can cause material injury that cannot be adequately redressed on appeal." Id. at 1100; see also Diaz-Verson v. Walbridge Aldinger Co., 54 So. 3d 1007, 1011 (Fla. 2d DCA 2010) (granting certiorari and quashing the trial court's order denying petitioner's motion for a protective order, concluding that petitioner's personal financial information was not relevant to the issues raised in the pleadings and disclosure of personal financial information would result in irreparable harm). Similarly, Olsen failed to plead partnership, the issue of the parties' relationship was definitively tried and determined by Judge Bailey, and the issue was not tried by consent.