Under New York law, the cause of action has four elements: (i) extreme and outrageous conduct; (ii) intent to cause, or disregard of a substantial probability of causing, severe emotional distress; (iii) a causal connection between the conduct and injury; and (iv) severe emotional distress.
Brown v. New York Design Ctr., Inc., NY Slip Op 01228 (1st Dep't March 9, 2023)
