RJW Media Inc. v. Heath, 2017 UT App 34 (Feb. 24, 2017)

Discussing the disclosure requirements for non-retained experts for the first time since the 2011 revision to the Utah Rules of Civil Procedure, the court of appeals held that the district court abused its discretion by allowing a party to present opinions of a non-retained expert, because the party failed to provide a summary of the witness’s testimony, as required by Rule 26, until four days prior to trial.