“Plaintiff claims that Defendant’s conduct caused him to suffer severe emotional distress. To establish this claim, Plaintiff must prove all of the following: 1. That Defendant’s conduct was outrageous; 2. That Defendant intended to cause Plaintiff emotional distress or That Defendant acted with reckless disregard of the probability that Plaintiff would suffer emotional distress, knowing that Plaintiff was present when the conduct occurred; 3. That Plaintiff suffered severe emotional distress; and 4. That Defendant’s conduct was a substantial factor in causing Plaintiff’s severe emotional distress.”
[CACI Jury Instructions [citations omitted]]
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