responded to Slue’s e-mail, and went to the same recipients, a common interest privilege might exist. Defendants do not make this argument, however, and the factual premise is not clearly established on the present record. Accordingly, the Court does not pass on any such claim of privilege. 16 . Intentional infliction of emotional distress is a residual tort, and plaintiff must allege extreme conduct that is not already an independent tort. Thus, any injury or emotional distress stemming from defendants' alleged defamation is already included in plaintiff’s libel and slander claims. See Restatement (Second) of Torts § 5 ch.24 (1977) (categorizing libel and slander as torts). 17 .See, e.g., Singh v. U.S. Security Assoc., No. 03 Civ.2059(FM), 2005 WL 236511, at *14 (S.D.N.Y. Feb.1, 2005) (<HOLDING>); Lawford v. N.Y. Life Ins. Co., 739 F.Supp.
holding that in being discharged employee did not sustain the direct physical impact required to maintain an action for negligent infliction of emotional distress holding emotional distress suffered must be severe and not trivial holding that a plaintiffs gardenvariety dispute with his former employer may have had a crushing impact on him and his family but was insufficient to sustain a severe emotional distress claim holding that plaintiffs outsized emotional reaction to car accident was not allowed as basis for emotional distress damages where reasonable person would have experienced some anger or been upset but would not have suffered severe distress recognizing that in some circumstances injuries based on embarrassment humiliation and emotional distress may be sufficient to sustain a  1983 claim