With no explanation, chose the best option from "A", "B", "C" or "D". 1342 (1986). Connecticut first recognized intentional infliction of emotional distress in an employment setting in the case of Murray v. Bridgeport Hospital, 40 Conn.Supp. 56, 62, 480 A.2d 610, 613 (1984). Following Murray, the courts have generally limited its application to extreme and outrageous conduct by the employer. See, e.g., Johnson v. Chesebrough-Pond’s USA Co., 918 F.Supp. 543, 553 (D.Conn.) (dismissing claim of intentional infliction of emotional distress, stating that although methods employed by plaintiffs supervisor in terminating him “may not have been ideal employment practices, they [did] not constitute ‘extreme and outrageous’ conduct”), aff'd, 104 F.3d 355 (2d Cir.1996); Jewett v. General Dynamics Corp., No. 530943, 1997 WL 255093 at *7 (Conn.Super., May 7, 1997) (<HOLDING>). In negligence cases, however, Connecticut

A: holding that two counseling statements similar to negative performance evaluations do not rise to level of materially adverse employment action required under title vii
B: holding that where the complaint alleged that the employer gave the plaintiff a poor performance review increased his sales goals by 42 and pressured him to take early retirement the conduct was not extreme and outrageous
C: holding employer discipline and written and verbal criticism of employees job performance not extreme and outrageous
D: holding that defendantemployers failure to follow mandatory personnel policies governing performance evaluations and its discipline and removal of plaintiff from his position without cause did not rise to the level of extreme and outrageous conduct
D.