What is the test for disclosure of evidence in a civil case?

^2. CALCRIM No. 306 provides in pertinent part: "Both the People and the defense must disclose their evidence to the other side before trial, within the time limits set by law. Failure to follow this rule may deny the other side the chance to produce all relevant evidence, to counter opposing evidence, or to receive a fair trial. An attorney for the (People/defense) failed to disclose: <describe evidence that was not disclosed> [within the legal time period]. In evaluating the weight and significance of that evidence, you may consider the effect, if any, of that late disclosure."

^3. Brady v. Maryland (1963) 373 U.S. 83, 87.