4520 REVIEW DENIED To recover for emotional distress resulting from observation of a physical injury being inflicted on a close relative, plaintiff must show that s/he was aware of the injury producing event when it occurred and was reasonably certain it caused injury; plaintiffs awareness of the event and belief that injury was more likely than not fails to sufficient to satisfy this burden.CitationRA v SUPERIOR COURT (Falling Sign) 154 CA4 142 [See: Dillon v Legg 68 C2 728; Thing v LaChusa 48 C3 644]
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