August 25, 2014, real party in interest, James Brown, filed a class action complaint for negligence, professional negligence, gross negligence, negligence per se, breach of fiduciary duty, tortious breach of fiduciary duty, and negligent

On January 28, 2015, the district court held a hearing on the motion and determined that a claim of professional negligence against a physician is medical malpractice and thus, an affidavit is required.

The record only demonstrates that the district court determined that Brown's professional negligence claim against the Rawson-Neal physicians was for medical malpractice and thus, needed a medical malpractice affidavit.

Despite these statements, on July 3, 2012, Luciano filed a complaint against Saint Mary's, the doctors at Saint Mary's, and SMPHIC, claiming: "As a result of the negligence and subsequent stroke, Robert Luciano suffered a mental

Woodard's colonoscopy and that his representation that he could perform the procedure was not fraudulent because he intended to have a supervising physician assist him at the time he made the representation.

Fraud as a separate claim from professional negligence In resolving this issue, this court must first address whether the district court properly found that Ms.

Woodard's colonoscopy and that his representation that he could perform the procedure was not fraudulent because he intended to have a supervising physician assist him at the time he made the representation.

Fraud as a separate claim from professional negligence In resolving this issue, this court must first address whether the district court properly found that Ms.

Egan held that, because a podiatrist was not a "physician" as defined in NRS 41A.013, the action was for "professional negligence," not for "medical malpractice," and NRS 41A.071 did not apply. Id. at 366-67 .