California, United States of America
The following excerpt is from Welch v. Brown, A146625 (Cal. App. 2017):
"The elements of a cause of action for intentional infliction of emotional distress are: ' "(1) outrageous conduct by the defendant, (2) intention to cause or reckless disregard of the probability of causing emotional distress, (3) severe emotional suffering and (4) actual and proximate causation of the emotional distress." ' " (Bikkina v. Mahadevan (2015) 241 Cal.App.4th 70, 87-88.)
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