Is there any case law that limits damages for negligent infliction of emotional distress to those who contemporaneously observe both the negligent act and the injury it causes?

Defendants argue that if the reasoning and rule of Thing v. La Chusa, supra, 48 Cal.3d 644, 667-668, 257 Cal.Rptr. 865, 771 P.2d 814, and Ochoa v. Superior Court (1985) 39 Cal.3d 159, 165, fn. 6, 216 Cal.Rptr. 661, 703 P.2d 1, limiting recovery for negligent infliction of emotional distress to those who contemporaneously observe both the negligent act and the injury it causes is not applied to the claims of these plaintiffs, then they will suffer liability that is out of all proportion to their culpability. ²⁶