What is the test for intentional infliction of emotional distress in a personal injury case?

In Ochoa, the defendants' conduct was directed primarily at plaintiffs' decedent. (Id. at pp. 172-173, 216 Cal.Rptr. 661, 703 P.2d 1.) In concluding that recovery was not available under an intentional infliction of emotional distress theory, we noted that to the extent such recovery had been allowed, it has been limited to " 'the most extreme cases of violent attack, where there is some especial likelihood of fright or shock.' " (Id. at p. 165, fn. 5, 216 Cal.Rptr. 661, 703 P.2d 1. Accord, Coon v. Joseph (1987) 192 Cal.App.3d 1269, 237 Cal.Rptr. 873.)