The following excerpt is from Gorrell v. Sneath, Case No.: 1:12-cv-00554-AWI-JLT (E.D. Cal. 2012):
California case law describes the elements of a prima facie case for the tort of intentional infliction of emotional distress as follows: (1) outrageous conduct by the defendant (2) the defendant's intention of causing or reckless disregard of the probability of causing emotional distress; (3) the plaintiff's suffering severe or extreme emotional distress; and (4) actual and proximate causation of the emotional distress by the defendant's outrageous conduct. Cote v. Henderson, 218 Cal. App. 3d 796, 805-806 (Cal. App. 2d Dist. 1990)
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