California, United States of America
The following excerpt is from Dunlap v. Ford, C076900 (Cal. App. 2018):
A trial court's determination of qualification of an expert will not be disturbed on appeal absent an abuse of discretion by the trial court. (Brown v. Colm (1974) 11 Cal.3d 639, 646-647 [in medical malpractice case, trial court abused discretion in excluding an expert based on his lack of personal experience with standard of care prevailing 23 years before trial].)
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