Zellerino v. Brown

In Zellerino v. Brown (1991) 235 Cal. App. 3d 1097, the plaintiff in a medical malpractice case ignored a court order setting a date for exchange of expert witness information, and waited until six days before trial to mail her list of experts to the opposing parties. In affirming the decision to exclude those experts, the court specifically found that plaintiff's conduct "prejudiced the defense, which did not have the ability to counter the testimony of the belatedly disclosed experts." (Id. at pp. 1117-1118.)