California, United States of America
The following excerpt is from Murdoch v. Brock Solutions, A143310 (Cal. App. 2017):
not a situation like the one in Fairfax v. Lords (2006) 138 Cal.App.4th 1019 (Fairfax). There, the defendant's expert witness designation listed no experts; several weeks later, the defendant provided a second designation naming two witnesses designed to counter the plaintiff's expert. (Id. at p. 1022, 1023.) Over the plaintiff's objection, the trial court allowed the defendant's experts to testify. (Id. at pp. 1024-1025.)
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