Waddell v. Titan Ins. Co
In Waddell v. Titan Ins. Co., 207 Ariz. 529, 88 P.3d 1141 (App. 2004), the defendant objected to previously undisclosed testimony regarding the plaintiff's possible need for surgery and that surgery's cost. Id. at 536, P27, 88 P.3d at 1148.
The plaintiff had disclosed the doctor's identity and the injury, and the defense chose not to depose the doctor even though counsel knew that the witness would testify regarding the plaintiff's prognosis. Id. at 536-37, PP27-31, 88 P.3d at 1148-49.
The Court held that a more complete disclosure would have been preferable, but the defense was not denied a reasonable opportunity to prepare for trial. Id. at 537, P33, 88 P.3d at 1149.