State v. Czajka

In State v. Czajka (1995), 101 Ohio App.3d 564, 656 N.E.2d 9, the Court held that "a trial court does not abuse its discretion by permitting the testimony of an undisclosed witness if it can be shown that the failure to provide discovery was not willful, that foreknowledge of the statement would not have benefitted the defendant in preparation of the defense, and that the defendant was not prejudiced by the admission of the evidence."