Can plaintiffs bring a fourth cause of action alleging intentional infliction of emotional distress for failure to exhaust administrative remedies?

conduct arising from sexual harassment such as battery, assault, or wrongful discharge, and need not exhaust administrative remedies before bringing such causes of action. (Rojo v. Kliger, supra, 52 Cal.3d at pp. 81, 88, 276 Cal.Rptr. 130, 801 P.2d 373.) Therefore, plaintiffs fourth cause of action, which purports to allege intentional infliction of emotional distress, is not demurrable for failure to exhaust administrative remedies. We express no opinion whether this purported cause of action satisfies other pleading requirements. (See Michaelian v. State Comp. Ins. Fund (1996) 50 Cal.App.4th 1093, 1113-1114, 58 Cal.Rptr.2d 133.)