California, United States of America
The following excerpt is from Reales Inv., LLC v. Johnson, 269 Cal.Rptr.3d 525, 55 Cal.App.5th 463 (Cal. App. 2020):
tape." ( Deeter, supra , at pp. 245-255, 224 Cal.Rptr. 801.) Similarly, in Castaline v. City of Los Angeles (1975) 47 Cal.App.3d 580, 121 Cal.Rptr. 786, the appellate court held the trial court did not abuse its discretion when it precluded the testimony of a "surprise witness" at trial who had not been disclosed to the opposing party.
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