In Newby v. Alto Riviera Apartments (1976) 60 Cal.App.3d 288, disapproved on other grounds in Marina Point, Ltd. v. Wolfson (1982) 30 Cal.3d 721, 740, footnote 9, the defendants, calling the plaintiff a "troublemaker" and accusing her of upsetting other tenants, gave her an eviction notice; however, they never filed an unlawful detainer. ( Newby, supra, at pp. 293-294.) The appellate court reversed a nonsuit on her cause of action for intentional infliction of emotional distress because it found sufficient evidence of severe emotional distress: "Appellant . . . was afraid that respondents would remove her and her belongings from the apartment. She was afraid she would be locked out and decided to stay home from work one day. Appellant testified that she was unable to sleep after respondents told her she would be 'handled the way they do down South.' Another witness testified that appellant called her at 6:30 a.m., to say she was alone and afraid. Appellant's voice was quavering. The witness stated: 'I never heard her ever speak in that tone of voice. '" ( Id., at pp. 298-299.) In Newby v. Alto Riviera Apartments (1976) the evidence showed that after the plaintiff tenant organized opposition to rent increases, the landlord shouted at the tenant and insulted her, directed her to vacate the premises. The plaintiff was also told if she did not leave ". . ., We will handle this the way we do down South." ( Id., pp. 297-298.) The court held this sufficient to meet the test of outrageous behavior.