Holding the "narrow" exception to the economic loss rule is "limited to a defendant's affirmative misrepresentations on which a plaintiff relies and which expose a plaintiff to liability for personal damages."
Holding that in obtaining a patient's consent to a procedure, "a physician must disclose personal interests unrelated to the patient's health, whether research or economic, that may affect the physician's professional judgment"
Explaining "[t]he party against whom a complaint ... has been filed may object, by demurrer ..., to the pleading" on the basis that "[t]he pleading does not state facts sufficient to constitute a cause of action"