In Martin-Johnson, Inc. v. Savage, 509 So. 2d 1097 (Fla. 1987), the Court recognized that to establish the type of irreparable harm necessary in order to permit certiorari review, a party cannot simply claim that continuation of the lawsuit would damage one's reputation or result in needless litigation costs. In Martin-Johnson, this Court held that an appellate court could not use a writ of certiorari to review an interlocutory order denying a motion to dismiss or strike a claim for punitive damages because the petitioner would have an adequate remedy by way of appeal. Martin-Johnson, 509 So. 2d at 1098. The Court distinguished the situation where a party was merely forced to continue with litigation and thus did not suffer "irreparable harm" from those situations where an order violated a party's "fundamental rights" and caused harm that could not be later remedied or that involved a discovery order that would cause a material injury of an irreparable nature because it was "cat out of the bag" material. Id. at 1099-1100. The Court explained the applicable limits of the use of petitions for writs of certiorari to appeal an order granting discovery. The Court described certiorari relief as an "extraordinary remedy" that "should not be used to circumvent the interlocutory appeal rule which authorizes appeal from only a few types of non-final orders." Id. at 1098. The Court observed that orders granting discovery had traditionally been reviewed by certiorari, because when discovery is wrongfully granted "the complaining party is beyond relief." Id. at 1099. However, we concluded that not every erroneous discovery order creates certiorari jurisdiction in an appellate court, and focused on "irreparable harm" as the governing standard. Id. at 1099. The Court found illustrative of this type of discovery order one that would let the "cat out of the bag" and provide the opponent material that could be used by an unscrupulous litigant to injure another person. Id. at 1100. The court emphasized that: "common law certiorari is an extraordinary remedy and should not be used to circumvent the interlocutory appeal rule which authorizes appeal from only a few types of non-final orders. Generally, all other appellate review is postponed until the matter is concluded in the trial court." 509 So. 2d at 1098. The court quoted from the advisory committee's note on the nonfinal appeal rule that: "It is extremely rare that erroneous interlocutory rulings can be corrected by resort to common law certiorari. It is anticipated that since the most urgent interlocutory orders are appealable under this rule, there will be very few cases where common law certiorari will provide relief." 509 So. 2d at 1099. The Martin-Johnson court further explained: "Litigation of a non-issue will always be inconvenient and entail considerable expense of time and money for all parties in the case. The authorities are clear that this type of harm is not sufficient to permit certiorari review. c.o. Moreover, if we permitted review at this stage, appellate courts would be inundated by petitions . . . and trial court proceedings would be unduly interrupted. Even when the order departs from the essential requirements of the law, there are strong reasons militating against certiorari review. For example, the party injured by the erroneous interlocutory order may eventually win the case, mooting the issue, or the order may appear less erroneous or less harmful in light of the development of the case after the order." 509 So. 2d at 1100.