California, United States of America
The following excerpt is from Younan v. Equifax Inc., 111 Cal.App.3d 498, 169 Cal.Rptr. 478 (Cal. App. 1980):
In Bowden v. Spiegel Inc. (1950) 96 Cal.App.2d 793, 216 P.2d 571, a complaint was held to state a cause of action for intentional infliction of emotional distress which alleged that defendant's agent telephoned plaintiff's neighbor at 11 p. m. asking that plaintiff be found to answer "an emergency call"; that when plaintiff answered, the caller demanded payment of a bill and threatened court action, in the hearing of members of the neighbor's family; that plaintiff owned no such bill and that the cause was made maliciously, to annoy plaintiff who became ill.
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