Austin v. Kaufman

In Austin v. Kaufman, 203 Ga. App. 704, 417 S.E.2d 660 (Ga. App. 1992), the Court of Appeals of Georgia upheld a trial court's decision to permit a medical examiner to testify as an expert witness even though the plaintiff failed to disclose during discovery that the medical examiner would be called. The court pointed out that the medical examiner did not acquire or develop his opinion in anticipation of litigation or trial, but further observed that the medical examiner had been identified as an expert witness in the pre- trial order.