result from negligent performance, not all cases of medical negligence, even if otherwise actionable, will give rise to liability for infliction of emotional dis tress. Judges will necessarily have to draw on their reservoir of knowledge of societal norms, as well as evidence of professional and ethical standards and norms of practice. See, e.g., Curtis, 956 P.2d at 963 (noting that standard of care required that precautions be taken to “avoid or minimize” psychological reaction to confinement during an MRI examination). There are evident differences between the duty of a hospital or obstetrician whose negligence results in death or permanent injury to a child during labor and delivery and thereby causes deep distress in the mother, Burgess, 9 Cal.Rptr.2d 615, 831 P.2d at 1199, 1203 (<HOLDING>); the duty of a doctor who negligently arrives
recognizing the unique relationship between mother and child during pregnancy and birth and permitting mothers claim for emotional distress where the mothers emotional wellbeing and the birth of the child are inextricably intertwined recognizing that substance abuse and emotional disturbance need not be inextricably intertwined holding evidence legally and factually sufficient under sections d and e to terminate mothers parental rights based in part on evidence that mother endangered childs physical and emotional wellbeing by leaving child alone overnight with known cocaine abusers recognizing claim for negligent infliction of emotional distress when medical malpractice during pregnancy resulted in stillborn child holding in a fcra case that plaintiffs may not rely on mere  conclusory statements  rather they must  sufficiently articulate  true demonstrable emotional distress  including the factual context in which the emotional distress arose evidence corroborating the testimony of the plaintiff the nexus between the conduct of the defendant and the emotional distress the degree of such mental distress mitigating circumstances if any physical injuries suffered due to the emotional distress medical attention resulting from the emotional duress psychiatric or psychological treatment and the loss of income if any