Denial of Discovery Upheld; Motion for Recusal Untimely

A litigant cannot complain about a lack of opportunity to conduct discovery when the litigant never petitioned the Orphans’ Court for leave to conduct discovery, as required by local rules. A motion for recusal is not timely when it is made after the court has issued a final decree. In re: Mitchell E. and Karlie M. Roth Irrevocable Trust, 1409 EDA 2024 (Pa. Super. 4/1/2026) (non-precedential).

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