Glowacki v. Underwood Memorial Hosp

In Glowacki v. Underwood Memorial Hosp., 270 N.J. Super. 1, 636 A.2d 527 (App.Div.1994), the Court held that, where the defendant had been formally notified and plaintiff moved after a trial on liability but before a trial on damages for the use of a vocational expert, the trial court was within its discretion to relax the exclusionary aspects of R. 4:17-7 "in the interests of justice". Id. at 13, 636 A.2d 527. The Court noted that the defendant had ample notification and an opportunity to consult an expert of its own. Id. at 14, 636 A.2d 527. Therefore, the defendant was neither surprised nor prejudiced by the trial court's decision to allow the new experts. Ibid.