" {ΒΆ 8} Regarding dismissal of RHI's complaint, the trial court reviewed the language of Civ.R. 34(D) and noted that the rule was promulgated in response to the Ohio Supreme Court's interpretation of R.C. 2317.48, in Poulos v. Parker Sweeper Co., 44 Ohio St.3d 124, 541 N.E.2d 1031 (1989). The court further stated that the rule and the statute together govern discovery actions.