What is the test for a cause of action for extreme and/or severe emotional distress?

With respect to the second element, Plaintiffs' allegations are plainly insufficient. Plaintiffs simply state that "[they] did, in fact, suffer extreme and/or severe emotional distress." SAC at 89. Plaintiffs fail to offer any facts that would show the nature or extent of their distress. See Hamilton v. Prudential Fin., No. 2:07-cv-00944-MCE-DAD, 2007 WL 2827792 (E.D. Cal. Sep. 27, 2007) (finding that plaintiff's allegations that he suffered from depression, frustration, nervousness, and anxiety lacked the necessary specificity to show their nature or extent). This cause of action fails on this basis.