Does a physician who worked as a consultant in an emergency room at a general acute care hospital qualify as an expert?

In support of their interpretation, defendants rely on Miranda v. National Emergency Services, Inc., supra, 35 Cal. App.4th 894, 41 Cal.Rptr.2d 593, arguing it held the five-year period was measured from the time of trial. Not so. Miranda did state that an expert witness was qualified under section 1799.110(c) "if he or she is a physician who has had `substantial professional experience,' within the five years preceding the trial, while employed or otherwise engaged by a general acute care hospital to provide treatment in its emergency room as an `emergency room physician.' [Citation.]" (Id. at p. 905, 41 Cal.Rptr.2d 593.) But this must be viewed in the context of the issue considered, whether a physician who worked sporadically as a consultant in an emergency room provided "emergency medical coverage" so as to be qualified as an expert. Although

[119 Cal.App.4th 1097]