Task: Text Completion
Input (English): denying recovery for negligent infliction of emotional distress because the plaintiffs were not physically present, cited with approval Dillon v. Legg, 68 Cal.2d 728, 69 Cal.Rptr. 72, 441 P.2d 912 (1968). Dillon directs the courts to look at various factors to- determine who can recover for the tort of negligent infliction of mental distress including whether the plaintiff and victim are “closely related.” Cases in California since Dillon have expressly held that a plaintiff must be closely related to recover for the negligent infliction of emotional distress. Elden v. Sheldon, 46 Cal.3d 267, 250 Cal.Rptr. 254, 758 P.2d 582 (1988) (plaintiff living together with victim in de facto marriage not “closely related”); Thing v. La Chusa, 48 Cal.3d 644, 257 Cal.Rptr. 865, 771 P.2d 814 (1989), (<HOLDING>). The Ninth Circuit has also recognized this 
 Holding statements: (A) holding that related provisions should be read together (B) holding that all related matters must be arbitrated (C) holding that plaintiff must present such evidence (D) recognizing that a mailing must be sufficiently related to the fraudulent scheme to support a charge of mail fraud (E) holding plaintiff must be closely related to victim
Output (English): (E)