There appears to be no requirement that the expert's proposed standard be the predominant or prevailing standard nationwide, so it would suffice for the expert to " ‘link his testimony to [a] certification process, current literature, conference[,] or discussion with other knowledgeable professionals,’ at a national level." Cardenas v. Muangman , 998 A.2d 303, 308 (D.C. 2010) (first alteration in original) (emphasis omitted) (quoting Strickland v. Pinder , 899 A.2d 770, 774 (D.C. 2006) ).
" Dan B. Dobbs, Undertakings and Special Relationships in Claims for Negligent Infliction of Emotional Distress, 50 ARIZ. L. REV. 49, 54 (2008) (hereinafter Undertakings and Special Relationships). In situations where such an undertaking is established, the plaintiff can recover damages for emotional distress caused by the defendant's breach of a duty of care that is defined in accordance with traditional precepts of negligence law; for example, where there is an allegation of medical malpractice, by reference to the national standard of care. See, e.g., Cardenas v. Muangman, 998 A.2d 303, 306 (D.C. 2010). Alabama does not recognize the separate tort of negligent infliction of emotional distress.