The following excerpt is from In re McClure, Case No.: 1:13-bk-10386-GM (Bankr. C.D. Cal. 2019):
This is different from negligent infliction of emotional distress. Intentional infliction is based on outrageous conduct, which is intentional or reckless and which is outside the bounds of decency. It must be especially calculated to cause mental distress and does cause a very serious kind of mental distress. Ochoa v. Superior Court, 39 Cal.3d 159, 165 fn. 5 (1985).
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