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1179 REVIEW GRANTED An action against a hospital for spoliation of evidence, based on the allegation that it destroyed evidence needed by plaintiff to establish a products liability claim against the manufacturer of hospital equipment, is not an action arising from professional negligence and is not subject to CCP 425.13 regarding punitive damages claims against health care providers.CitationTEMPLE v SUPERIOR COURT (Hospital Spoliation) 43 CA4 595 [See: Augusta v United 13 CA4 4, T/AT 4/93; Coca-Cola v Superior Court 233 CA3 1273; Ernst v Fireman's 14 CA4 930, T/AT 6/93; Smith v Superior Court 151 CA3 491; United v Superior Court 42 CA4 500, T/AT 3/96; Cedars-Sinai v Superior Court 43 CA4 50, T/AT 4/96]
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