December 8, 2025
Superior Court of California, County of Santa Clara, Appellate Division
The Rule of Spring Oaks Capital SPV, LLC v. Fowler is that a party who fails to properly disclose witness names and addresses in response to a Code of Civil Procedure section 96 request cannot call that undisclosed witness at trial, under circumstances where the responding party only provided the witness's role without specific name identification and the requesting party properly objected.