The goal of California’s statutory scheme governing presentation of evidence in the case-in-chief “is to avoid surprise at trial. (Staub v. Kiley (2014) 226 Cal.App.4th 1437, 1444, 1447, 173 Cal.Rptr.3d 104 (Staub); see also Deyo v. Kilbourne (1978) 84 Cal.App.3d 771, 781, 149 Cal.Rptr. 499 (Deyo) [“discovery laws were designed to prevent trial by ambush”].)
Surprise at trial is unfair. It also is inefficient.” (emphasis in original.)