California, United States of America
The following excerpt is from Gorden-Cave v. Bartram, B276360 (Cal. App. 2017):
action accrues. (Code Civ. Proc., 312.) The tort of intentional infliction of emotional distress "is not complete until the effect of a defendant's conduct results in plaintiff's severe emotional distress. That is the time the cause of action accrues and starts the statute of limitations running." (Kiseskey v. Carpenters' Trust for So. California (1983) 144 Cal.App.3d 222, 232.) " 'Both the intensity and duration of the emotional distress suffered must be considered in determining its severity. Severe emotional distress means "emotional distress of such substantial quantity or enduring quality that no reasonable man in a civilized society should be expected to endure it." ' " (Id. at p. 231.)
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