In Shipman v. Fontaine Truck Equipment Co, 184 Mich. App. 706, 714; 459 N.W.2d 30 (1990), the Court reversed a grant of JNOV in favor of defendant Fontaine. In its brief on appeal, Fontaine argued, in the alternative, that if this Court reversed the JNOV, a new trial should be granted because plaintiffs failed to supplement discovery responses and because of allegedly improper jury instructions given during trial. The trial court had rejected these alternative arguments. The Court ruled that because the issues were not cross-appealed, they were not properly before this Court and would not be addressed. Id.