The following excerpt is from Farren v. Select Portfolio Servicing, Inc., No. 2:16-cv-01077-JAM-DB (E.D. Cal. 2017):
The elements for the tort of intentional infliction of emotional distress are: (1) extreme and outrageous conduct by the defendant with the intention of causing, or with reckless disregard of the probability of causing, emotional distress; (2) plaintiff suffered severe or extreme emotional distress; and (3) actual and proximate causation of the emotional distress by defendant's outrageous conduct. Hughes v. Pair, 46 Cal. 4th 1035, 1050 (2009). "Outrageous conduct has been defined as conduct that is so extreme as to exceed all bounds of that usually tolerated in a civilized community and so extreme and outrageous as to go beyond all possible bonds [sic] of decency, and to be regarded as atrocious, and utterly intolerable in a
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