California, United States of America
The following excerpt is from Pina v. Cnty. of L. A., 251 Cal.Rptr.3d 17, 38 Cal.App.5th 531 (Cal. App. 2019):
No. 16.1 did not require exclusion of his testimony, given that appellant identified no applicable court order and no evidence that the County's failure was willful. ( Mitchell v. Superior Court (2015) 243 Cal.App.4th 269, 272, 196 Cal.Rptr.3d 168 ["[E]xclusion of a party's witness for that party's failure to identify the witness in discovery is appropriate only if the omission was willful or a violation of a court order compelling a response"].)
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