Can a judge resort to expert testimony to establish a standard of care?

A judge may resort to expert testimony to establish the standard of care when that standard is not a matter of common knowledge or where the attorney is practicing in a specialized field. In this case, the court itself was the trier of fact, and defendants' conduct did not constitute violations for which expert testimony was required. "They were violations of professional standards; standards which the trial court was compelled to notice. (Evid.Code, 451, subd. (c).)" ( Day v. Rosenthal, supra, 170 Cal.App.3d at p. 1147, 217 Cal.Rptr. 89.) There was no error.

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C. Timeliness of Action