party claiming privilege in Pennsylvania

2022See J.C., 179 A.3d at 1130 (explaining that, in a custody case, relief is not warranted unless the party claiming error suffered prejudice from the mistake).

2020In custody cases involving the harmless error doctrine, the question is whether the party claiming error “suffered prejudice from the mistake.” See J.C. v. K.C., 179 A.3d 1124, 1130 (Pa. Super. 2018) (citing Harman ex el.

2025A party claiming this exception must make a “clear showing that the remedy is inadequate.” Commonwealth v. Eisenberg, 454 A.2d 513, 515 ([Pa.] 1982).

2023A party claiming this exception must make a “clear showing that the remedy is inadequate.” Commonwealth v. Eisenberg, . . . 454 A.2d 513, 515 ([Pa.] 1982).

2025Keystone ReLeaf LLC, 186 A.3d at 517 .

2021A party claiming this exception must make a “clear showing that the remedy is inadequate.” Id.

2014Morningstar v. Mifflin County School District, 760 A.2d 1221 (Pa.Cmwlth.2000).

2014See also Morningstar v. Mifflin County School District, 760 A.2d 1221 (Pa.Cmwlth.2000); Hecknauer v. Coder, 32 Pa.Cmwlth. 308 , 379 A.2d 638 (1977).

2023See id.

2022See Pa.R.A.P. 302(a) (“Issues not raised in the trial court are waived and cannot be raised for the first time on appeal”); see also Tecce v. Hally, 106 A.3d 728, 732 (Pa. Super. 2014) (“Parties may waive rights, even due process rights and other rights of constitutional magnitude” (citation omitted)); Morgan v. Morgan, 117 A.3d 757, 762 (Pa. ____________________________________________ 5Mother listed three additional questions involved in this appeal, but expressly stated that she “waives” those issues in the argument section of her brief.

2022See Pa.R.A.P. 302(a) (“Issues not raised in the trial court are waived and cannot be raised for the first time on appeal”); see also Tecce v. Hally, 106 A.3d 728, 732 (Pa. Super. 2014) (“Parties may waive rights, even due process rights and other rights of constitutional magnitude” (citation omitted)); Morgan v. Morgan, 117 A.3d 757, 762 (Pa. ____________________________________________ 5Mother listed three additional questions involved in this appeal, but expressly stated that she “waives” those issues in the argument section of her brief.

2021See Rae, supra, 977 A.2d at 1125 (if the three-pronged “test is not met, and in the absence of another exception to the final order rule, we have no jurisdiction to consider an appeal of such an order”).11 ____________________________________________ 10 We specifically disapprove of a court itself producing documents to any party after an in camera review, since doing so may deprive the affected party of any continuing right to contest production and cause irreparable harm to the party claiming privilege. 11 We observe, but do not herein decide, that in the event Erie is ordered, after an in c

2021See Rae, supra, 977 A.2d at 1125 (if the three-pronged “test is not met, and in the absence of another exception to the final order rule, we have no jurisdiction to consider an appeal of such an order”).11 ____________________________________________ 10 We specifically disapprove of a court itself producing documents to any party after an in camera review, since doing so may deprive the affected party of any continuing right to contest production and cause irreparable harm to the party claiming privilege. 11 We observe, but do not herein decide, that in the event Erie is ordered, after an in c

2020Harman v. Borah, 756 A.2d 1116, 1122 (Pa. 2000)).

2011See Commonwealth v. Hess, 270 Pa.Super. 501 , 411 A.2d 830, 833 (1979), appeal dismissed as improvidently granted, 499 Pa. 206 , 452 A.2d 1011 (1982).

2011See Commonwealth v. Hess, 270 Pa.Super. 501 , 411 A.2d 830, 833 (1979), appeal dismissed as improvidently granted, 499 Pa. 206 , 452 A.2d 1011 (1982).

2011See Commonwealth v. Hess, 270 Pa.Super. 501 , 411 A.2d 830, 833 (1979), appeal dismissed as improvidently granted, 499 Pa. 206 , 452 A.2d 1011 (1982).

2011See Commonwealth v. Hess, 270 Pa.Super. 501 , 411 A.2d 830, 833 (1979), appeal dismissed as improvidently granted, 499 Pa. 206 , 452 A.2d 1011 (1982).

2005Joe v. Prison Health Services Inc., 782 A.2d 24, 32 (Pa. Commw. 2001).

2000Clearly lacking from the Supreme Court’s decision in Kohler is any requirement that there must be a showing of personal animus; 4 rather, the party claiming the exception must show only that injuries were inflicted for “purely personal reasons”, reasons “purely personal to the assailant.” Kohler, 532 Pa. at 137-38 , 615 A.2d at 30-31 . ¶ 17 Second, the cited proposition from Hershey itself was derived from Mike v. Borough of Aliquippa, 279 Pa.Super. 382 , 421 A.2d 251 (1980) wherein this Court was not as absolute.

2000Clearly lacking from the Supreme Court’s decision in Kohler is any requirement that there must be a showing of personal animus; 4 rather, the party claiming the exception must show only that injuries were inflicted for “purely personal reasons”, reasons “purely personal to the assailant.” Kohler, 532 Pa. at 137-38 , 615 A.2d at 30-31 . ¶ 17 Second, the cited proposition from Hershey itself was derived from Mike v. Borough of Aliquippa, 279 Pa.Super. 382 , 421 A.2d 251 (1980) wherein this Court was not as absolute.

1996See e.g., Pittston Co. v. Allianz Insurance Co., 143 F.R.D. 66, 71 (D.N.J. 1992) (at issue waiver is inapplicable where the plaintiff in an environmental coverage claim has not sought to use or inject any privileged documents as a part of a claim or defense); Remington Arms Co. v. Liberty Mutual Insurance Co., 142 F.R.D. 408, 415 (D.

1996See e.g., Pittston Co. v. Allianz Insurance Co., 143 F.R.D. 66, 71 (D.N.J. 1992) (at issue waiver is inapplicable where the plaintiff in an environmental coverage claim has not sought to use or inject any privileged documents as a part of a claim or defense); Remington Arms Co. v. Liberty Mutual Insurance Co., 142 F.R.D. 408, 415 (D.