not clear as to the recipients of this communication. The copy of the e-mail in the record is actually of an email that Freedberg sent to Slue on February 20, 2004, informing him that he had sent an e-mail "to the Department,” and incorporating the text of that e-mail. (Citak Aff. Ex. DD.) The parties appear to assume that the email went to essentially the same people as Slue’s e-mail, and as Freedberg's January 26 and February 5 e-mails. 15 . To the extent that Freedberg's February 20 e-mai 919 (S.D.N.Y.1990) (finding that plaintiff's claims that his former employer’s failure to pay his pension benefits led to his severe emotional distress did not meet the strict New York standard for such a claim); Kirwin v. N.Y. State Office of Mental Health, 665 F.Supp. 1034, 1040 (E.D.N.Y.1987)
holding that mere insults indignities and threats are not extreme and outrageous acts holding emotional distress suffered must be severe and not trivial 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 plaintiffs allegations of isolation ostracization and harassment campaign by the defendant merely amounted to insults indignities annoyances and petty oppressions which did not meet the strict burden required under new york law for severe emotional distress 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