What is the test for severe or extreme emotional distress in a personal injury action?

plaintiff suffered severe or extreme emotional distress; and (3) the plaintiff's injuries were actually and proximately caused by the defendant's outrageous conduct. [Citation.]" (Cochran v. Cochran (1998) 65 Cal.App.4th 488, 494.) In order to meet the first element, the alleged conduct "'". . . must be so extreme as to exceed all bounds of that usually tolerated in a civilized community." [Citation.]'" (Ibid.) "[T]he tort does not extend to 'mere insults, indignities, threats, annoyances, petty oppressions, or other trivialities . . . .' [Citations.]" (Id. at p. 496, quoting Rest.2d Torts, 46, com. d, p. 73.)