literal reading of § 523(a)(2)(A) is inconsistent with our case law. See In re Levy, 951 F.2d 196, 198 (9th Cir.1991) (section 523(a)(2)(A) “limits nondis-ehargeability to the amount of benefit to the debtor or loss to the creditor the act of fraud itself created”). An action for nondischarge-ability under § 523(a)(2)(A) requires only: (1) a representation; (2) falsity; (3) scienter; (4) reliance; and “(5) that the creditor sustained the alleged loss and damage as the proximate result of the representations having been made.” In re Britton, 950 F.2d at 604. Malpractice is a foreseeable result of any medical procedure, id. at 604-05, and the fifth element can be proved if the debtor fraudulently induced the creditor to undergo a procedure that was then negligently performed. Id. at 605 (<HOLDING>). Lee-Benner alleged damage from negligent
holding finding of reliability not clearly erroneous despite lack of prior description holding that the district courts finding of no discrimination under title vii was not clearly erroneous because the finding was supported by the record holding that the district courts finding of no discrimination was not clearly erroneous because the finding was supported by the record holding clearly erroneous bankruptcy courts conclusion that mobile home was property of the estate holding bankruptcy courts finding of proximate causation not to be clearly erroneous