To prevail on negligent infliction of emotional distress, a plaintiff must prove: 1.) the defendant's conduct created an unreasonable risk of causing emotional distress; 2.) the plaintiff's distress was foreseeable; 3.) the distress was severe enough to result in illness or bodily harm; and 4.) the defendant's conduct caused the plaintiff's distress.
Chin v. D'Agostino
March 21, 2012