On failure to provide timely expert witness disclosures

In Saudi v. Northrop Grumman Corp., Judge Wilkinson wrote:

"Rule 37(c)(1) provides that '[a] party that without substantial justification fails to disclose information required by Rule 26(a) . . . is not, unless such failure is harmless, permitted to use as evidence at trial . . . any witness or information not so disclosed.' A district court may also impose 'other appropriate sanctions.' Id. Rule 26 disclosures are often the centerpiece of discovery in litigation that uses expert witnesses. A party that fails to provide these disclosures unfairly inhibits its opponent’s ability to properly prepare, unnecessarily prolongs litigation, and undermines the district court’s management of the case. For this reason, '[w]e give particularly wide latitude to the district court’s discretion to issue sanctions under Rule 37(c)(1).' S. States Rack & Fixture, 318 F.3d at 595 (internal quotation marks omitted)."