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Vanlaningham v. Hart, 2021 UT App 95 (Sept. 2, 2021)

The district court excluded plaintiff’s special damages-related evidence from trial because her initial disclosure of a “specific sum” of $130,000 in special damages failed to provide “a mathematical computation” or the “methodology” behind the amount. On an interlocutory appeal, the court of appeals affirmed, holding that a plaintiff disclosing a specific sum, without more, does “not provide a computation as required by rule 26(a)(1)(C).” “Defendants were left to guess at the components of and how [plaintiff]  calculated her $130,000 special damages claim.”