and loan officers who were allegedly negligent in approving bad loans; it does not involve the same kind of intentional and abhorrent conduct present in Bouterie. Therefore, we will not extend the doctrine beyond the four traditional categories in this case. 18 . See, e.g., Palowsky v. Premier Bancorp, Inc., 597 So.2d 543, 545 (La.Ct.App.1992) (noting that "a shareholder may ... sue to recover losses to a corporation resulting from mismanagement and breaches of fiduciary duties [on the part of its directors] secondarily through a shareholder's derivative suit.”). 19 . See Rogers, 42 F.3d at 295 (stating that the third category “is applied in situations involving concealment, fraud, misrepresentation and other ill practices.”); Fontenot v. ABC Ins. Co., 674 So.2d 960, 963 (La.1996) (<HOLDING>). 20 . Because we hold that contra non valentem
recognizing differing elements and standard of proof between medical malpractice and fraud holding that a north carolina rule requiring an expert certification in a medical malpractice case applied in a federal tort claims act case sounding in medical malpractice brought in federal court holding that a plaintiff cannot avoid the securities fraud exception by pleading mail fraud or wire fraud if the conduct giving rise to those offenses also amounts to securities fraud recognizing fraud to be a known misrepresentation or a nondisclosure holding in a medical malpractice case that to trigger application of the third category a physicians conduct must rise to the level of concealment misrepresentation fraud or ill practices