California, United States of America
The following excerpt is from Sobayo v. Sosa, A147501 (Cal. App. 2017):
Sobayo's cause of action for emotional distress is based entirely on the alleged conduct in his three earlier causes of action for libel, abuse of process, and unlawful debt collection. It thus stands or falls with them. (See Seelig v. Infinity Broadcasting Corp. (2002) 97 Cal.App.4th 798, 812.)
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