may reasonably expect that the mother will not be far distant and will upon witnessing the accident suffer emotional trauma.” Id., 69 Cal.Rptr. 72, 441 P.2d at 921. The court stated that three factors should guide the determination whether alleged mental distress was "reasonably foreseeable” in such circumstances: (1) the proximity of the plaintiff to the incident; (2) whether the mental distress was contemporaneous with the plaintiff’s observation of the incident; and (3) the blood relationship between the plaintiff and the victim. Id., 69 Cal.Rptr. 72, 441 P.2d at 919-20. 11 . The California Supreme Court has subsequently added limiting requirements to the "foreseeability” test articulated in Dillon. See Thing v. La Chusa, 48 Cal.3d 644, 257 Cal.Rptr. 865, 771 P.2d 814, 829-30 (1989) (<HOLDING>). 12 . Williams made clear that a direct victim
holding that a plaintiff may recover damages for emotional distress caused by observing the negligently inflicted injury of a third person if but only if said plaintiff 1 is closely related to the injury victim 2 is present at the scene of the injury producing event at the time it occurs and is then aware that it is causing injury to the victim and 3 as a result suffers serious emotional distress holding in a fcra case that plaintiffs may not rely on mere  conclusory statements  rather they must  sufficiently articulate  true demonstrable emotional distress  including the factual context in which the emotional distress arose evidence corroborating the testimony of the plaintiff the nexus between the conduct of the defendant and the emotional distress the degree of such mental distress mitigating circumstances if any physical injuries suffered due to the emotional distress medical attention resulting from the emotional duress psychiatric or psychological treatment and the loss of income if any holding that intentional infliction of emotional distress is a personal injury tort holding that a tort claim for intentional infliction of emotional distress is distinct from a claim for emotional distress damages under the employment discrimination statute recognizing that when a defendants negligence causes bodily injury the plaintiff can recover damages for past present and future medical expenses bodily injury and emotional distress