In Delaney v. Baker (1999) 20 Cal. 4th 23, 42, 971 P.2d 986, the question before the Supreme Court was whether a health care provider charged with the "reckless neglect" of a deceased elder within the meaning of section 15657 could be liable for attorneys' fees and emotional distress damages. The question arose because of an apparent inconsistency between section 15657 and a related section in the Elder Abuse Law, section 15657.2, which provides: "Notwithstanding this article, any cause of action for injury or damage against a health care provider, as defined in section 340.5 of the Code of Civil Procedure the MICRA statute of limitations governing actions against health care providers, based on the health care provider's alleged professional negligence, shall be governed by those laws which specifically apply to those professional negligence causes of action." According to the defendant in Delaney, the reference in section 15657.2 to a claim "based on . . . professional negligence" covers all conduct directly related to the rendition of professional services (not just negligence) -- and exempts health care providers from the heightened remedies of section 15657, notwithstanding a finding that the health care provider has recklessly neglected an elder. ( Delaney v. Baker, supra, 20 Cal. 4th at pp. 30-31.) The Supreme Court rejected the health care provider's broad reading of section 15657.2 and analyzed the problem this way: "The starting point of our analysis is the language of the statutes themselves. 'Professional negligence' in section 15657.2 is defined elsewhere as a 'negligent act or omission to act by a health care provider in the rendering of professional services.' ( Code Civ. Proc., 340.5.) Generally 'negligence' is the failure '"to exercise the care a person of ordinary prudence would exercise under the circumstances."' 'Professional negligence' is one type of negligence, to which general negligence principles apply. . . .