To establish liability for any of these intentional torts, the plaintiff must prove that the defendant intended certain consequences of his conduct. To establish this, the plaintiff must prove one of two things:
1. That it was the defendant’s purpose to bring about certain tortious consequences, or 2. That the defendant knew that those tortious consequences were substantially certain to occur.
The plaintiff will have a good claim against the defendant for intentional infliction of emotional distress if the plaintiff can prove by a preponderance of the evidence that the defendant engaged in extreme and outrageous conduct, and through that conduct intentionally or recklessly caused the plaintiff to suffer severe emotional distress.