How have courts dealt with disclosure of witness statements in a sexual assault trial?

decision. The trial court could reasonably find that defendant should have anticipated that it was likely he would call as witnesses defendant's family members who purportedly knew about the victim's denial of the offense, a primary issue in the case. (People v. Tillis (1998) 18 Cal.4th 284, 287, citing Izazaga v. Superior Court (1991) 54 Cal.3d 356, 376, fn. 11.) The trial court could reasonably find that defendant should have disclosed the witness statements at least 30 days before the trial began.

Finally, defendant did not make any showing of "good cause" as defined by the statute for deferring disclosure, e.g., that disclosure of the witnesses' names raised concern about the witnesses' safety or the loss of evidence. Instead, defense counsel's explanation was that he did not believe the testimony of the witnesses would be required and that the possibility of using their testimony did not occur to him until he was practicing his opening statement. Accordingly, the trial court did not err in finding that defendant had violated the discovery statutes. (People v. Riggs (2008) 44 Cal.4th 248, 306.)