California, United States of America
The following excerpt is from Smith v. Pust, 19 Cal.App.4th 263, 23 Cal.Rptr.2d 364 (Cal. App. 1993):
However, it is not enough that an act be outrageous to state a cause of action for intentional infliction of emotional distress. Intentional means more than the nonaccidental nature of the wrongful act. That act must also be directed at the plaintiff or in the presence of the plaintiff. (Christensen v. Superior Court, supra, 54 Cal.3d at p. 903, 2 Cal.Rptr.2d 79, 820 P.2d 181 ["It is not enough that the conduct be intentional and outrageous. It must be conduct directed at the plaintiff, or occur in the presence of a plaintiff of whom the defendant is aware."].)
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