for establishing an indirect claim for emotional distress that is based on medical malpractice are strictly applied. See Frame, supra, 115 N.J. at 651-52, 560 A.2d 675 (observing that expansion of medical malpractice to include indirect claims of emotional distress may increase actual and social costs of providing health care) (Wilentz, C.J., and Garibaldi, J., concurring). Medical malpractice giving rise to emotional-injury claims can involve obstetrical malpractice that occurs in the course of pregnancy with resultant serious or fatal injuries to the fetus or newborn and consequent severe emotional distress suffered by the parents. E.g., Carey v. Lovett, 132 N.J. 44, 622 A.2d 1279 (1993); Giardina, supra, 111 N.J. 412, 545 A.2d 139. In those cases, the Court h d 834 (1981) (<HOLDING>); Berman v. Allan, 80 N.J. 421, 432, 404 A.2d 8
holding that parents could assert direct claim for emotional distress against doctor who failed to inform them of genetic risk of having another 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 holding that a tort claim for intentional infliction of emotional distress is distinct from a claim for emotional distress damages under the employment discrimination statute holding that family could assert claim for negligent infliction of emotional distress against doctor who negligently interpreted a german measles test thereby depriving parents of opportunity to consider terminating pregnancy holding that doctors failure to inform parents of availability of amniocentesis that deprived parents of opportunity to terminate pregnancy forms basis of direct claim for negligent infliction of emotional distress