absence of another exception in Pennsylvania

2021If the test is not met, however, and in the absence of another exception to the final order rule, there is no jurisdiction to consider an appeal of such an order.” Shearer, 177 A.3d at 857 .

2020Commonwealth v. Kennedy, 876 A.2d 939 , 943 n.3 (Pa. 2005). 7 v. Hafer, 177 A.3d 850, 857 (Pa. 2018) (stating, “[i]f the [collateral order] test is not met . . . and in the absence of another exception to the final order rule, there is no jurisdiction to consider an appeal of such an order”).

2024“If the test is not met, however, and in the absence of another exception to the final order rule, we have no jurisdiction to consider an appeal of such an order.” Id. -5- The first prong of collateral order doctrine, separability, is met where review of the order in question does not implicate the merits of the underlying dispute.

2021If the test is not met, however, and in the absence of another exception to the final order rule, we have no jurisdiction to consider an appeal of such an order.” Rae v. Pennsylvania Funeral Directors Ass’n, 977 A.2d 1121 , 1125 (Pa. 2009). -6- J-E01012-20 is true. [The trial judge’s] cautious approach actually preserves privilege or work product to the extent such rights are established where an insurer has delegated the duties of investigation and evaluation to an attorney.

2020Commonwealth v. Kennedy, 876 A.2d 939 , 943 n.3 (Pa. 2005). 7 v. Hafer, 177 A.3d 850, 857 (Pa. 2018) (stating, “[i]f the [collateral order] test is not met . . . and in the absence of another exception to the final order rule, there is no jurisdiction to consider an appeal of such an order”).

2018See Commonwealth v. Kennedy, 583 Pa. 208 , 876 A.2d 939, 943 , (2005) (finding a Rule 313 issue is “an issue of [an appellate court’s] jurisdiction to entertain an appeal”).

2024“As an exception to the rule of finality, the collateral order rule is interpreted narrowly, and each prong must be satisfied before an order will be considered on appeal.” Sylvan Heights Realty Partners, L.L.C. v. LaGrotta, 940 A.2d 585, 587 (Pa. Cmwlth. 2008); accord Rae, 977 A.2d at 1129.

2023“As an exception to the rule of finality, the collateral order rule is interpreted narrowly, and each prong must be satisfied before an order will be considered on appeal.” Sylvan Heights Realty Partners, L.L.C. v. LaGrotta, 940 A.2d 585, 587 (Pa. Cmwlth. 2008); see Brooks, 259 A.3d at 373.

2022However, “an appeal from a discovery order raising a question of the application of a privilege is separable from the underlying issue, so long as the issue of privilege may be addressed by an appellate court without analysis of the underlying issue.” Id., quoting Castellani v. Scranton Times, L.P., 916 A.2d 648, 652 (Pa. Super. 2007).

2022However, “an appeal from a discovery order raising a question of the application of a privilege is separable from the underlying issue, so long as the issue of privilege may be addressed by an appellate court without analysis of the underlying issue.” Id., quoting Castellani v. Scranton Times, L.P., 916 A.2d 648, 652 (Pa. Super. 2007).

2022As for the second prong, importance, “it is not sufficient that the issue be important to the particular parties.” Instead, the issue “must involve rights deeply rooted in public policy going beyond the particular litigation at hand.” We must interpret the collateral order doctrine narrowly, and each of the above prongs must be clearly present for us to deem an order collateral. “[T]he question of whether the collateral order doctrine has been met is jurisdictional in nature.” “Where an order satisfies Rule 313’s three-pronged test, an appellate court may exercise jurisdiction even though the

2017Grp., 143 A.3d 930, 936 (Pa. Super. 2016) (some citations omitted). “[W]here an order satisfies Rule 313’s three-pronged test, we may exercise appellate jurisdiction where the order is not final..If the test is not met, however, and in the absence of another exception to the final order rule, we have no jurisdiction to consider an appeal of such an order.” Rae v. Pennsylvania Funeral Directors Ass’n, 602 Pa. 65 , 977 A.2d 1121 , 1125 (2009).