Florida Judge Belvin Perry adjourned court early on Monday in the Casey Anthony murder trial.
By joint stipulation, we are in recess until 9 a.m., he said, according to the Orlando Sentinel.
Anthony has been charged with first-degree murder in the death of her 2-year old daughter Caylee Anthony.
On Monday, Perry expressed frustration after a prosecutor said he intended to call for sanctions against the defense for failing to disclose information about what defense witnesses were going to testify about.
Defense Attorny Jeff Ashton said he was late in getting various materials from Dutch forensic expert Richard Eikelenboom.
Perry called the moves gamesmanship.
It is quite evident there is a friction between attorneys, Perry said.
Perry also said he would not allow another defense witness to testify until prosecutors could review his deposition made on Saturday after he gave opinions on the stand not previously included in reports to the prosecution.
Casey Anthony could face the death penalty if convicted of smothering Caylee with duct tape on June 16, 2008, as the prosecution alleges. Casey's defense attorneys say Caylee drowned on June 16 at Casey's parents' home in Orlando, Florida.
Caylee was not reported missing for 31 days and her skeleton was discovered 6 months later near the parents' home.