What is the state court cause of action against Defendant for intentional infliction of emotional distress?

MultiRegion, United States of America

The following excerpt is from Zambo v. Jeffries (In re Jeffries), Adv No: 1:17-ap-01023-MT, Case No.: 1:16-bk-13445-MT (Bankr. C.D. Cal. 2018):

The state court cause of action against Defendant for which damages may be nondischargeable is intentional infliction of emotional distress, and not assault. See People v. Williams, 26 Cal. 4th 779, 790 (holding that assault does not require a specific intent to cause injury or a subjective awareness of the risk that an injury might occur).

1. Identical Issue

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