Is a plaintiff's cause of action for intentional infliction of emotional distress deficient?

Plaintiffs' cause of action for intentional infliction of emotional distress is equally deficient. That cause of action requires, among other things, extreme and outrageous conduct causing the plaintiff to suffer severe or extreme emotional distress. (Hughes v. Pair (2009) 46 Cal.4th 1035, 1050, 95 Cal.Rptr.3d 636, 209 P.3d 963.) A defendant's conduct is outrageous' when it is so extreme as to exceed all bounds of that usually tolerated in a civilized community. ' (Id. at pp. 10501051, 95 Cal.Rptr.3d 636, 209 P.3d 963.) Liability does not extend to mere insults, indignities, threats, annoyances, petty oppressions, or other trivialities. [Citation.] (Id. at p. 1051, 95 Cal.Rptr.3d 636, 209 P.3d 963.) Severe emotional distress means emotional distress of such substantial quality or enduring quality that no reasonable [person] in civilized society should be expected to endure it. ' (Ibid. )