California, United States of America
The following excerpt is from Mirtorabi v. Action Foreclosure Servs., Inc., B252084 (Cal. App. 2015):
While defendants' conduct was unprofessional, this was a business deal in which defendants exercised their rights under the first trust deed to declare a default and proceed with foreclosure. There is no showing that "in conducting the foreclosure proceedings any of the defendants threatened, insulted, abused or humiliated [plaintiffs]. Thus, [plaintiffs] cannot state a claim for intentional infliction of emotional distress." (Wilson v. Hynek (2012) 207 Cal.App.4th 999, 1009.)
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