Appellate counsel often need to consider the effect of new trial orders on issue preservation, especially during retrials. Once a new trial is granted, whether by an appellate or trial court, "the necessary effect … is to set aside the prior judgment and leave the case … precisely in the same condition as if no previous trial had been held." See Commonwealth v. Hart, 387 A.2d 845, 847 (Pa. 1978). Or, in other words, "an order for a new trial wipes the slate clean." See Commonwealth v. Sattazahn, 763 A.2d 359, 369 (Pa. 2000), aff'd, 537 U.S. 101 (2003).