In Gibbs v. Bureaus Inv. Group Portfolio No. 14, LLC, 441 S.W.3d 764 (Tex. App.--El Paso 2014, no pet.), the court rejected the argument that Gibbs suffered no surprise simply because "Gibbs bore the responsibility to 'inquire about or request additional information as to who exactly the designated witness for Bureaus would be or to attempt to seek additional information once the witness was designated.'" Id. at 768. The court did so because: 1) Bureaus was "not excused from complying with the rules of civil procedure" and 2) the "contention eviscerates Rule 193.6(a)'s 'salutary effect of promoting full and complete discovery and instead invites trial by ambush, the very peril the promulgation of the rules of discovery sought to avert.'" Id. A "party . . . 'is entitled to prepare for trial assured that a witness will not be called because opposing counsel has not identified him or her in response to a proper interrogatory.'" Id.