Holding that plaintiffs' cause of action for fraud "aris[es] out of the professional negligence of a health care provider" for purposes of Code of Civil Procedure section 425.13
Requiring facts pled in the complaint to "rise to the level of malice, oppression or fraud necessary under Civil Code section 3294 to state a claim for punitive damages"
73 Cal.App.3d 864 (Cal. Ct. App. 1977) Cited 38 times
Holding that the "conclusory characterization of defendant's conduct as intentional, willful and fraudulent" was "patently insufficient" to support the recovery of punitive damages