McDonald v. Zargaryan (2025)
B329565; filed 12/22/25.
![[Files/CaseFiles/B329565.PDF]]
[Opinion PDF](https://www.courts.ca.gov/opinions/archive/B329565.PDF)
## Rule excerpts
Late expert designation without a reasonable justification; Code of Civil Procedure sections 2034.300 and 2034.610.
> The absence of a reasonable justification meant allowing this tardy witness to testify was an abuse of discretion. Of course, some late designations can have valid justifications. Long-designated experts may suddenly become unavailable: death, illness, incapacitation, and other serious and uncontrollable events can create an understandable need for replacements. The world’s supply of unexpected and unfortunate events is varied and unlimited.
— McDonald v. Zargaryan (2025), slip op., p. 9.