OPINION
We granted certiorari to review the trial court’s preclusion of witness testimony as a sanction against defendant Mark McCarty for failure to comply with a demand for notice of alibi. The court of appeals affirmed. Because the trial court abused its discretion in precluding testimony under the facts and circumstances of this case, we reverse.
Sometime between the late hours of May 17 and the early morning hours of May 18, 1986, Schumpert’s Music Company (Schumpert’s) in Roswell was burglarized. McCarty was arrested and charged with five felony offenses in connection with that burglary. Subsequently, the State filed a demand for notice of alibi pursuant to SCRA 1986, 5-508.1 The defense did not submit a notice of alibi, but filed a witness list containing the names and addresses of two witnesses, Pat Gordon and Debbie Gilkison, without identifying them as alibi witnesses.
During the trial, defense counsel attempted to offer testimony to impeach the story of the State’s key witness, Donny Chapman, to the effect that defendant left Kathy’s Arcade with Keith Moore and Chapman around 9:00 p.m. or 10:00 p.m. Gordon would have testified that McCarty was at the arcade until 12:15 a.m. Before Gordon was able to testify to this fact, the State objected on the grounds that this was evidence establishing an alibi defense of which it was not notified. A sidebar conference ensued and defense counsel argued that this was not alibi evidence because the witness would not corroborate the where*652abouts of McCarty at the time of the alleged burglary offenses, which the defense asserted occurred after 1:00 a.m. The trial judge ruled that this was evidence of an alibi and he would not permit Gordon to testify regarding time.2 When defense counsel continued to protest, the trial judge excused the jury and heard argument on the issue. The trial judge reiterated his position that if Chapman’s testimony was that McCarty left the arcade between 9:00 p.m. and 10:00 p.m., drove around a little bit, cased Schumpert’s, and then burgled the place, and that Gordon was going to testify that McCarty was at the arcade until after 12:15 a.m., then that would indeed be an alibi defense. Gilkison, the other defense witness, was also precluded from testifying that she was with McCarty until around 12:30 a.m.
Alibi is a shorthand description for a defense that rests on the fact that the accused was elsewhere at the time the alleged offense took place. State v. Horenberger, 119 Wis.2d 237, 242, 349 N.W.2d 692 (1984); see State v. Redwine, 79 Or. App. 25, 27, 717 P.2d 1239, 1241 (Alibi evidence is evidence that the defendant was, at the time of the commission of the alleged offense, at a place other than the place where such offense was committed.), cert. granted, 301 Or. 338, 722 P.2d 737 (1986); State v. Berg, 697 P.2d 1365, 1367 (Mont.1985) (“An alibi is a defense that places the defendant at the relevant time in a different place than the scene involved and so removed therefrom as to render it impossible for the defendant to be the guilty party.”). Alibi evidence focuses on the defendant’s activities at the time of a specific act which is itself a violation of the criminal statute. The defendant’s whereabouts during the alleged planning stages of the crime do not constitute an alibi defense for the crime itself. Horenberger, 119 Wis.2d at 243-44, 349 N.W.2d at 695-96.
Chapman’s testimony elicited on direct examination regarding the actual time of the burglary offenses was as follows:
Q. Do you have any idea what time it was when you went, actually entered Schumpert’s music store?
A. No, I didn’t.
Q. Sometime either the 17th or early on the 18th?
A. I guess it was around you know 1:00 or 2:00 on the 18th but I am not sure.
As regards the events that took place after the first entry, Chapman testified that after removing the instruments from the store and placing them in McCarty’s car, they drove to Moore’s house where they remained for approximately one and one-half to two hours. Chapman and McCarty subsequently returned to Schumpert’s and took another keyboard. McCarty then drove to his house where he and Chapman sat in the car and talked awhile before McCarty drove Chapman home at 4:42 a.m.
During the argument to the court, defense counsel agreed to go on record that the challenged testimony would not establish an alibi. McCarty had no witness to corroborate his testimony that he was at home asleep at the time the offenses occurred. Defense counsel argued that the purpose of the testimony of both defense witnesses was to impeach Chapman’s testimony that he, McCarty and Moore left the arcade between 9:00 p.m. and 10:00 p.m.
In Taylor v. Illinois, 484 U.S. 400, 108 S.Ct. 646, 98 L.Ed.2d 798 (1988), the Supreme Court held that the compulsory process clause of the sixth amendment does not create an absolute bar to the preclusion of a defense witness’ testimony as a sanction for violating a discovery rule requiring disclosure of witnesses. Although a trial court may not ignore the fundamental character of the defendant’s right to offer the testimony of witnesses in his favor, “the mere invocation of that right cannot automatically and invariably outweigh countervailing public interests.” Id. at 655. While this decision put to rest the notion that “the sixth amendment forbids the exclusion of otherwise admissible evi*653dence solely as a sanction to enforce discovery rules or orders against criminal defendants,” United States v. Davis, 639 F.2d 239, 243 (5th Cir.1981), the facts underlying the Taylor court’s holding suggest that preclusion is only appropriate in limited circumstances.
In Taylor, on the second day of trial, defense counsel made an oral motion to amend his discovery response to include two more witnesses. Defense counsel represented that he had just been informed about these witnesses and that they probably had seen the entire incident. The trial judge directed counsel to bring the witnesses in the next day, at which time he would decide whether they could testify. At the hearing, the witness “acknowledged that defense counsel had visited him at his home on the Wednesday of the week before the trial began. Thus, his testimony rather dramatically contradicted defense counsel’s representations to the trial court.” Taylor, 108 S.Ct. at 650.
A trial judge may certainly insist on an explanation for a party’s failure to comply with a request to identify his or her witnesses in advance of trial. If that explanation reveals that the omission was willful and motivated by a desire to obtain a tactical advantage that would minimize the effectiveness of cross-examination and the ability to adduce rebuttal evidence, it would be entirely consistent with the purposes of the Confrontation Clause simply to exclude the witness’ testimony.
Id. at 655-56.
Although the Taylor court declined to draft a comprehensive set of standards to guide the exercise of discretion in cases involving preclusion as a sanction, the Court did cite as one example the balancing test announced in Fendler v. Goldsmith, 728 F.2d 1181 (9th Cir.1983). Taylor, 108 S.Ct. at 655 n. 19.
At the outset we emphasize that for a balancing test to meet Sixth Amendment standards, it must begin with a presumption against exclusion of otherwise admissible defense evidence. No other approach adequately protects the right to present a defense. See Washington v. Texas, [388 U.S. 14, 19, 87 S.Ct. 1920, 1923, 18 L.Ed.2d 1019 (1967)].
728 F.2d at 1188. Fendler addressed general criminal discovery rules, and specifically noted that the validity of the preclusion provision of the notice-of-alibi discovery rule, which is designed to deal with a particular type of evidence, was not before the court. “[T]he Supreme Court has specifically upheld such rules — though leaving open the question of what sanctions are permissible — because of the special tendency of unexpected alibi defenses to cause unfair surprise and lengthy trial delays.” Id. at 1188 n. 12, 1190 n. 20. Unlike the dissent in this case, we do not see Taylor or Fendler as holding the balancing test inapplicable to the notice-of-alibi discovery rule. It simply was not under consideration. No generalization can be made that pretrial notice of an alibi defense is either more or less significant than notice of witnesses to be called.
The Fendler court gave consideration to the following factors: (1) the effectiveness of less severe sanctions, (2) the impact of preclusion on the evidence at trial and the outcome of the case, (3) the extent of prosecutorial surprise or prejudice, and (4) whether the violation was willful. See also Escalera v. Coombe, 826 F.2d 185 (2d Cir. 1987), vacated and remanded, — U.S. -108 S.Ct. 1004, 98 L.Ed.2d 971 (1988). In deciding whether or not to admit alibi evidence when a proper notice has not been served by the defendant, the trial court should balance the potential for prejudice to the prosecution against the impact on the defense and whether the evidence might have been material to the outcome of the trial. Id. at 189-91. However, “[t]he integrity of the adversary process, which depends both on the presentation of reliable evidence and the rejection of unreliable evidence; the interest in the fair and efficient administration of justice; and the potential prejudice to the truth-determining function of the trial process must also weigh in the balance.” Taylor, 108 S.Ct. at 655.
*654Under the Fendler criteria, the factors here against levying a preclusion sanction predominate. The impact of the preclusion on the evidence at trial was significant. The jury was denied the opportunity to hear testimony from sworn witnesses that saw McCarty at the arcade during the time that Chapman testified McCarty was cruising the environs around Schumpert’s and casing the store. Furthermore, the extent of prosecutorial surprise or prejudice was de minimus. During argument to the court, defense counsel asked how the State was prejudiced because the prosecutor had spoken to each witness about particular times. In response, the prosecutor admitted that it was true that she had spoken with Gordon and, briefly, with Gilkison. The prosecutor then stated she would withdraw her objectipn. However, the trial judge replied that he would not “make” the prosecutor withdraw the objection, and stated “I will rule in your favor, unless, if you wish to withdraw it fine, if you don’t I will hold it is an alibi defense and that notice was not given.”
In his explanation for his failure to comply with notice of alibi, defense counsel claimed that the demand was too vague to respond to meaningfully. The notice requested McCarty to give specific information as to the places he claimed to have been between May 17th through June 13th, 1986, in Roswell, Chaves County, during which time he stood accused of burglary, receiving stolen property, contributing to the delinquency of a minor, larceny, and conspiracy. The trial judge responded that given the various charges it would have been impossible to be more particular concerning times of the alleged offenses. Furthermore, the trial judge stated that if defense counsel required more particularity or a breakdown of the charges, he should have requested such assistance from either the district attorney or the court. The trial judge opined that a defense counsel relies at his own peril upon an excuse for failing to comply with a discovery request. We agree, and do not rest our decision on any claim that it was unreasonable for the trial court to characterize the testimony in question as alibi evidence within the scope of the demand for notice.
Although defense counsel in this case may be considered to have failed to comply strictly with the State’s notice of alibi, it would not have been unreasonable for the court to have deemed testimony on the whereabouts of the defendant during planning stages for the crime as not constituting alibi evidence. Other factors militate against a finding of willful misconduct on the part of defense counsel. He did disclose McCarty’s only witnesses four months prior to trial. Through its interview of McCarty’s witnesses, the State was cognizant of the particular times these witnesses would testify that McCarty was present at Kathy’s Arcade. Unlike the defense counsel in Taylor, McCarty’s counsel did not attempt to gain tactical advantage by producing undisclosed witnesses immediately prior to trial. In fact, during its interview of Gordon, the State discovered evidence adverse to McCarty and subsequently called her as a rebuttal witness. “The principal reason for notice rules * * * is prevention of surprise to the state, not punishment of the accused for mere technical errors or omissions.” Alicea v. Gagnon, 675 F.2d 913, 924 (7th Cir.1982).
“Notice-of-alibi rules * * * are based on the proposition that the ends of justice will best be served by a system of liberal discovery which gives both parties the maximum possible amount of information with which to prepare their cases and thereby reduces the possibility of surprise at trial.” Wardius v. Oregon, 412 U.S. 470, 473, 93 S.Ct. 2208, 2211, 37 L.Ed.2d 82 (1973). These rules enhance the search for truth by ensuring both the State and the defendant have ample opportunity to investigate certain facts crucial to the determination of guilt or innocence. Williams v. Florida, 399 U.S. 78, 82, 90 S.Ct. 1893, 1896, 26 L.Ed.2d 446 (1970). Neither the purpose nor intent behind the notice-of-alibi rule appears to have been frustrated here. The State had the opportunity to prepare its case by interviewing disclosed witnesses and investigating facts necessary to adjudicate the guilt or innocence of the defendant.
*655It is clear that a trial court does have the discretion to preclude defense testimony as a sanction for failure to comply with a demand for notice of alibi. SCRA 1986, 5-508(C). Preclusion, however, constitutes a conscious mandatory distortion of the fact-finding process whenever applied. See Weinstein, Some Difficulties in Devising Rules for Determining Truth in Judicial Trials, 66 Colum.L.Rev. 223, 227 (1966). Before a defendant’s sixth amendment rights are derogated as a sanction for noncompliance, a trial judge must exercise his discretion within recognized parameters. He must consider other available ways to enforce a criminal discovery rule.
Before resorting to preclusion, a trial judge should weigh not only the prejudicial effect of noncompliance on the immediate case, but also the necessity to enforce the rule to preserve the integrity of the trial process. See Taylor, 108 S.Ct. at 655. The trial judge should consider whether the noncompliance was a willful attempt to prevent the State from investigating facts necessary for the preparation of its case. The trial judge then must balance the resulting prejudice to the State against the materiality of the precluded testimony to the outcome of the case.
Here, the trial judge abused his discretion because under the facts and circumstances of this case it would be unreasonable to weigh the balance against the defendant. Defense counsel’s failure to give notice of his witnesses in the context of the notice-of-alibi rule did not frustrate the presentation of the State’s case. The State was able to interview the defendant’s only two witnesses to discern the substance of their testimony. There was no prejudice to the State, but the precluded testimony was critical to the defense’s ability to impeach the credibility of the State’s key witness, Donny Chapman. Unlike the dissent to this opinion, we do not characterize the conduct of defense counsel as willful. No harm is done to the integrity of the notice-of-alibi rule by prohibiting the preclusion of witness testimony as a sanction under such circumstances.
We reverse the conviction of McCarty and remand for a new trial.
IT IS SO ORDERED.
SOSA, Senior Justice, and WALTERS, J., concur.
SCARBOROUGH, C.J., and STOWERS, J„ dissent.