In Bellamy v. Appellate Department (1996) 50 Cal.App.4th 797, the plaintiff sued a hospital for general negligence and premises liability, after she allegedly fell off an X-ray table on which she "was left unattended" and unsecured. (Id. at p. 799.) The trial court sustained the defendant's demurrer without leave to amend on the ground the plaintiff's action was barred by the former one-year statute of limitations for personal injury actions. (Former 340, subd. (3).) In opposition to the demurrer, the plaintiff had contended she was subject to the notice requirement for professional negligence actions against health care providers and had served the required notice within 90 days of expiration of the statute of limitations period, which extended her time for filing suit for 90 days after service of notice thereby making her complaint timely filed under section 364, subdivision (d). The Court of Appeal agreed and reversed. (Bellamy, at p. 809.) Bellamy reasoned that section 340.5 defines professional negligence as "'a negligent action or omission ... in the rendering of professional services'" (Bellamy, supra, 50 Cal.App.4th at p. 805), and a broad reading of the facts showed "the hospital was rendering professional services to ..." the plaintiff "either in preparation for, during, or after an X-ray exam or treatment" (id. at pp. 805-806). According to Bellamy, "this result is consistent with Murillo v. Good Samaritan Hospital (1979) 'The test under Murillo is whether the negligent act occurred in the rendering of services for which the health care provider is licensed.'" (Id. at p. 806.) Because the complaint sufficiently alleged facts amounting to professional negligence, the court concluded it fell within section 364 and the complaint was timely filed. (50 Cal.App.4th at p. 809.) In sum, a patient brought an action for medical malpractice for damages sustained from her fall from a x-ray table. In evaluating where the complaint was time-barred, the Court concluded that the failure to properly secure a patient relative to the taking of x-rays constituted professional negligence within the meaning of Code of Civil Procedure section 364 and the Medical Injury Compensation Reform Act. The Court did not evaluate manner of proof by which negligence can or must be established.