State v. Mallozzi

Summary

The court affirmed the judgment affirming the defendant’s convictions, holding that the trial court did not abuse its discretion by denying a request made during trial to present a previously undisclosed handwriting expert. The late disclosure was a substantial departure from the defense’s obligations, the claimed surprise was avoidable because the expert’s broader conclusion appeared in the arrest-warrant affidavit, and the defense made no meaningful proffer of the proposed testimony.