UJI 13-1628. Intentional infliction of emotional distress.

To recover for intentional infliction of emotional distress, ________________ (name of plaintiff) must prove that: (1) the conduct of ______________ (name of defendant) was extreme and outrageous under the circumstances; and (2) ______________ (defendant) acted intentionally or recklessly; and (3) as a result of the conduct of _____________ (defendant), ____________ (plaintiff) experienced severe emotional distress. Extreme and outrageous conduct is that which goes beyond bounds of common decency and is atrocious and intolerable to the ordinary person. Emotional distress is “severe” if it is of such an intensity and duration that no ordinary person would be expected to tolerate it.