In Moreno v. Greater N.Y. Dental Adm'rs (120 A.D.2d 343 [1st Dept 1986]), the First Department required a plaintiff to provide defendant with the medical report from a consultant nontreating physician who was not going to be called to testify at trial. In ordering the disclosure, the First Department noted that the medical report exchange rules "advance the truth-determining function of trial and speedy disposition of cases . . . With the advent of liberal disclosure rules, there was an abandonment of the notion that the results of trial would be based on tactics or surprise; the outcome is to be based on the facts as developed through meaningful preparation prior to trial"