California, United States of America
The following excerpt is from Martin v. Nationstar Mortg. LLC, A146236 (Cal. App. 2018):
To plead intentional infliction of emotional distress, a plaintiff must plead facts showing " ' " ' "(1) extreme and outrageous conduct by the defendant with the intention 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." ' " ' [Citations.]" (Hughes v. Pair (2009) 46 Cal.4th 1035, 1050.)
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