California, United States of America
The following excerpt is from Finsand v. Nationstar Mortg., LLC, H045052 (Cal. App. 2019):
The elements of the tort of intentional infliction of emotional distress are (1) extreme and outrageous conduct by the defendant; (2) extreme or severe emotional distress to the plaintiff; and (3) actual and proximate causation between the two. (Potter v. Firestone Tire & Rubber Co.(1993) 6 Cal.4th 965, 1001.) To be outrageous, the defendant's conduct must be either intentional or reckless, and it must be so extreme as to exceed all bounds of decency in a civilized community. (Ibid.)
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