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Name: People v. Lamb
Case #: C046556
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 01/31/2006

Defense counsel’s failure to disclose information from an accident reconstruction expert violated the rules of discovery. Penal Code section 1054.3 requires the defense to disclose any “statements of experts made in connection with the case.” The defense argued below that it was not required to disclose an expert’s notes made in lieu of a formal report. The notes contained witness interviews, calculations, and observations arising from inspection of the cars involved in the incident. The trial court properly concluded that the defense had violated the rules of discovery, since the material covered under section 1054.3 is not limited to written reports.