What is the test for intentional infliction of emotional distress in a nonjudicial foreclosure action?

Beriones's fourth cause of action for intentional infliction of emotional distress required Beriones to establish (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 emotional distress by the defendant's outrageous conduct. (Wilson v. Hynek (2012) 207 Cal.App.4th 999, 1009.) In an action arising out of nonjudicial foreclosure proceedings, a trial court properly sustains a demurrer to this cause of action where, like here, the borrower has not pled facts showing "outrageous" conduct by defendants. (Ibid.) Beriones simply alleged in her complaint that the foreclosure caused her the "emotional nightmare of losing the [p]roperty." "At most, this was a creditor/debtor situation, whereby defendants were exercising their rights under the loan agreements. There are no allegations that in conducting the foreclosure proceedings any of the defendants threatened, insulted, abused, or humiliated [Beriones]." (Ibid.) Beriones thus failed to state a cause of action for intentional infliction of emotional distress.