tort claim that holds a party liable for extreme or outrageous conduct committed by the defendant’s negligence. Because of its tendency to expose parties and insurers to uncertain and widespread liability, many jurisdictions do not recognize it as a cause of action or have abolished it. See Boyles v. Kerr, 855 S.W.2d 593 (1993); Marlene F. v. Affiliated Psychiatric Medical Clinic, Inc., 48 Cal.3d 583, 257 Cal.Rptr. 98, 101, 770 P.2d 278, 281 (1989)
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