See, e.g. Robinson v. LeCorps, 83 S.W.3d 718 (Tenn. 2002);Higgins, supra; Crews v. United Ben. Ins. Of Omaha, Neb., 63 Tenn. App. 376, 472 S.W.2d 887 (1971). In Simpson, the trial court re-opened the proof after closing statements by counsel, apparently on its own motion.

We, however, believe that the allowance of the supplementary proof was a matter well within the sound discretion of the trial judge. Parties have been allowed to reopen the proof after both parties have rested, Crews v. United Beneficial Ins. Co. of Omaha, 472 S.W.2d 887 (Tenn.Ct.App. 1971); after the defendant moved for a directed verdict, Bellisomi v. Kenney, 206 S.W.2d 787 (Tenn. 1948); after closing arguments, Thompson v. Clendening, 38 Tenn. 287 (1858); and in rebuttal, although the evidence should have been introduced as a part of the plaintiff's proof in chief.