To establish a claim for intentional infliction of mental suffering, a plaintiff must plead the following material facts: flagrant or outrageous conduct by the defendants that was calculated to harm the plaintiff; and which caused the plaintiff to suffer a visible and provable medical illness: Frame v. Smith, 1987 CanLII 74 (SCC), [1987] 2 S.C.R. 99 at 127-128.
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