The following excerpt is from Joseph v. Target Corp., No. 2:12-cv-01962-KJM-EFB (E.D. Cal. 2015):
The elements of an IIED claim are: "(1) extreme and outrageous conduct by the defendant with the intent of causing, or reckless disregard of the probability of causing, emotional distress; (2) the plaintiff's suffering severe or extreme emotional distress; and (3) actual and proximate causation of the emotional distress by the defendant's outrageous conduct." Wynes v. Kaiser Permanente Hospitals, 936 F. Supp. 2d 1171, 1194 (E.D. Cal. 2013).
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