People v. Phillips

We granted leave to appeal in this case to determine whether MCR 6.201 permits a trial judge to compel a party in a criminal case to create reports from an expert witness when no such report exists. The plain language of MCR 6.201(A) applies only to providing reports that already exist. Therefore, we conclude that a trial court may not compel a party in a criminal case to create an expert witness report. We also conclude that while MCR 6.201(1) permits modification of the requirements or prohibitions of MCR 6.201 upon a showing of “good cause,” such good cause was not demonstrated in this…