During the recess after the plaintiff's argument and prior to the defendant's argument, the defendant's counsel objected to the plaintiffs counsel "mentioning that a hundred and fifty dollars ($150.00) an hour is the only price, so far, that has been put on the relief of an hour's worth of pain, smacks of suggesting a figure and/or a formula which is precisely why the Connecticut Supreme Court ruled as it did last week on the cases [Carchidi v. Rodenhiser, 209 Conn. 526, 551 A.2d 1249 (1989), and Pool v. Bell, 209 Conn. 536, 551 A.2d 1254 (1989),] that were appealed with regard to mentioning a money figure to the jury both as an opinion; and mentioning a money figure to the jury with regard to a formula . . . but I would move that the Court, prior to my argument, issue a brief instruction to the jury that a figure suggested by Mr. Tremont is in no way indicative, and should not be considered by them as an appropriate amount or suggestion as to what an hour's worth of pain or suffering or whatever is worth." He continued: "And also, it's misleading because what's going on in a surgical procedure, where you're opening up a part of the body, and removing bone or removing scar tissue is not the same sort of thing that Mr. Vajda testified to here in the courtroom.

Accordingly, because the trial court did not determine that any of the factors that mandate preclusion under Practice Book (2008) § 13–4(4) were applicable, and the record provides support for this determination, we conclude that the trial court did not abuse its discretion in allowing Marr to testify and in denying the defendants' request for a continuance. The defendants' reliance on our decision in Pool v. Bell, 209 Conn. 536, 551 A.2d 1254 (1989), to support their claim is misplaced. In Pool, we upheld the trial court's decision to preclude an expert witness who was disclosed belatedly when “the trial court could reasonably have viewed the late date at which the defendant disclosed [the expert] as the sort of ‘cat and mouse’ game that the rules of discovery and production were designed to discourage”; id. at 541, 551 A.2d 1254; but the court's specific rationale was not available because the hearing had not been transcribed.

(Citations omitted; emphasis added; internal quotation marks omitted.) Pool v. Bell, 209 Conn. 536, 542, 551 A.2d 1254 (1989). General Statutes § 52-184c does not require experts to have gained their knowledge by any particular method, such as from practice or experience, nor at any particular time.

While this Court now requires nearly identical curricula vitae between defendant and witness, other states generally accept witnesses based not on their particular specialties but on the extent of their knowledge. In Pool v. Bell, 209 Conn. 536, 551 A.2d 1254 (1989) (superseded by statute on other grounds), the Connecticut Supreme Court allowed a neurologist to testify as an expert against a general surgeon, despite the fact that the witness was not a professional clone of the defendant. "[T]he crucial question is whether the expert knows what the standards of practice are."

Other courts have likewise seen fit to reject the contention made here by the defendants that a medical professional must possess the same formal certifications as a defendant to give expert opinion in a medical malpractice case. See, e.g., Pool v. Bell, 551 A.2d 1254, 1258 (Conn. 1989); Fitzmaurice v. Flynn, 356 A.2d 887, 892 (Conn. 1975); Letch v. Daniels, 514 N.E.2d 675, 677 (Mass.

The plaintiffs assert that the defendants, by disclosing these experts in the manner in which they did, engaged in the "cat and mouse game" that timely disclosure is meant to prevent. See Pool v. Bell , 209 Conn. 536, 541, 551 A.2d 1254 (1989). In Pool , our Supreme Court decided that a trial court's decision to preclude an expert witness from testifying when a party elected to disclose that witness only three weeks prior to the start of trial, having consulted with that expert for more than one year and having received a court order to disclose experts during that time, was not an abuse of discretion on the basis of the facts of that case.

Here, the Waterbury Hospital defendants in their motion to preclude cited prejudice in the preparation of their case and bad faith on the part of the plaintiff as justifications for the requested sanction. In Pool v. Bell, 209 Conn. 536, 540, 551 A.2d 1254 (1989), a party failed to comply with the trial court's orders and instead waited until just weeks before trial to disclose an expert witness. Our Supreme Court concluded that the trial court's decision to preclude the expert's testimony was an appropriate response to what reasonably could be viewed as an abusive trial tactic.

" (Citations omitted.) Pool v. Bell, 209 Conn. 536, 541, 551 A.2d 1254 (1989); see also Gaudio v. Griffin Health Services Corp., 249 Conn. 523, 548-49, 733 A.2d 197 (1999). "There are no precise facts that must be proved before an expert's opinion may be received in evidence.

"A trial court's decision on whether to impose the sanction of excluding the testimony of a party's expert rests within the court's sound discretion." Pool v. Bell, 209 Conn. 536, 541 (1989); Barrows v. J.C. Penney Co., 58 Conn. App. 225, 231 (2000). In exercising such discretion the court must be mindful that our "discovery rules are designed to facilitate trial proceedings and to make a trial less a game of blind-man's buff and more a fair contest with the basic issues of fact disclosed to the fullest practical extent."

The court found it fundamentally unfair under the facts and circumstances of this case, where the defendants did not admit liability, to force them to the choice of making no alternative suggestion as to any dollar amount or formula to influence the jury's verdict, or making a suggestion of a sum when the theory on which the case had been tried by the defendants was that the jury should find a defendants' verdict and award nothing. In recent cases of Carchidi v. Rodenhiser, 209 Conn. 526 (1988) and Poole v. Bell, 209 Conn. 536 (1988), the Connecticut Supreme Court held it impermissible for counsel to argue the jury value or mathematical formulae for determining monetary value of damages in civil actions. Some excerpts from those decisions deserve particular mention. In Carchidi the court states that "The plaintiff points out that our holding in Levin v. Ritson, 179 Conn. 223, (1979) expressly authorizes counsel, with the permission of the court, to argue the value of a case. . . ."