that allegations of stress, humiliation, embarrassment, injury to reputation, and mental anguish unaccompanied by objective physical injury, medical attention, or lost income are not sufficient to support a claim for intentional infliction of emotion distress. Russo v. White, 241 Va. 23, 28, 400 S.E.2d 160, 163 (1991); see also Dotson v. U-Haul Co., 42 Va. Cir. 121 (Fairfax Co. 1997); Rollins v. Consolidated Bank & Trust Co., 54 Va. Cir. 147 (Richmond 2000). However, Russo and its progeny addressed emotional distress claims that were “independent of any physical injury and unaccompanied by any physical impact,” 241 Va. at 24, 400 S.E.2d at 161, and clearly differ from cases involving physical or sexual assaults. See Hygh v. Geneva Enters., Inc., 47 Va. Cir. 569, 575 (Fairfax Co. 1997) (<HOLDING>). In the cases at hand, the Plaintiffs have
holding that an alleged victim of sexual assault need not plead with graphic specificity any additional objective physical injury  and clearly experiences severe emotional distress that no reasonable person could be expected to endure holding that the issue of whether distress was so extreme that no reasonable person could be expected to endure it is a question of law 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 emotional pain and a need for counseling combined with physical pain medical bills loss of employment and a need for sexual therapy supported a claim of intentional infliction of emotional distress holding emotional distress suffered must be severe and not trivial