Motion for Leave To Submit a Tardy Expert Witness Designation [Memorandum of Points & Authorities] with supporting authorities for the arguments including a reasonable failure to disclose; statutory requirements of surprise, mistake or excusable neglect; the circumstances mandate relief; moving party did not improperly rely on a reservation of rights; his conduct was not willful concealment; the opposing party will not be prejudiced; public policy favors relief; the court has discretion to grant relief consistent with the showing; the trial court ruling presumed correct. 30 pages.