What constitutes multiple levels of hearsay in a medical report?

multiple levels of hearsay. An emergency room report, for example, may record the observations made by the writer, along with statements made by the patient. If offered for its truth, the report itself is a hearsay statement made by the person who wrote it. Statements of others, related by the report writer, are a second level of hearsay. Multiple hearsay may not be admitted unless there is an exception for each level. (People v. Riccardi (2012) 54 Cal.4th 758, 831, 144 Cal.Rptr.3d 84, 281 P.3d 1 (Riccardi ).) For example, in the case of the emergency room document, the report itself may be a business record (Evid.Code, 1270 et seq. ), while the patient's statement may qualify as a statement of the patient's existing mental or physical state (Evid.Code, 1250, subd. (a) ).

[374 P.3d 327]

B. State Evidentiary Rules for Expert Testimony