The following excerpt is from Dillman v. Tuolumne Cnty., 1:13-CV-00404 LJO SKO (E.D. Cal. 2013):
Defendants concede that a plaintiff can recover for emotional distress resulting from negligent conduct that causes injury to a family member under either a "bystander" or "direct victim" theory. Burgess v. Superior Court, 2 Cal. 4th 1064, 1071 (1992):
Id. at 1072-73 (internal citations omitted).
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