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0740 A phlebotomist's action against a hospital for injuries she sustained when attacked by a patient about whose combative propensities the hospital failed to warn was an action arising from the professional negligence of a health care provider and, therefore, subject to CCP 425.13 (requiring leave of the court for inclusion of a punitive damages claim).CitationWILLIAMS v SUPERIOR COURT (Blood Drawing) 30 CA4 318 [See: CCP 425.13; Central Pathology v SuperCt 3 C4 181; Hedlund v SuperCt 34 C3 695]
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