California, United States of America
The following excerpt is from Smith v. Bank of Am., N.A., F066194, F066470 (Cal. App. 2014):
The elements of the tort of intentional infliction of emotional distress are: (1) extreme and outrageous conduct by the defendant with the intention of causing, or reckless disregard of the probability of causing, emotional distress; (2) the plaintiff's suffering severe or extreme emotional distress; and (3) actual and proximate causation of the emotional distress by the defendant's outrageous conduct. (Christensen v. Superior Court (1991) 54 Cal.3d 868, 903.) Conduct to be outrageous must be so extreme as to exceed all bounds of that usually tolerated in a civilized community. (Ibid.) "'Liability has been found only where the conduct has been so outrageous in character, and so
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