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Sleepy Holdings LLC v. Mountain W. Title, 2016 UT App 62 (Mar. 31, 2016)

Plaintiff attempted to serve two supplemental disclosures addressing damages and naming witnesses over a year after the discovery cutoff. The district court struck both disclosures. Affirming, the Court of Appeals held Utah R. Civ. P. 26(a) and 37(f) govern the sanction when a party fails to timely make or supplement an initial disclosure, as opposed to Rule 16.