The obvious screwup is the paragraph numbering. That glitch occurs multiple times in the document, but the bigger problem for TDPK is in the paragraph numbered 36. (It’s actually the second paragraph 36.
The tort of intentional infliction of emotional distress has four elements: (1) the defendant must act intentionally or recklessly; (2) the defendant’s conduct must be extreme and outrageous; and (3) the conduct must be the cause (4) of severe emotional distress. While Kimberlin whines a lot in his multi-version complaint, he doesn’t allege with any specificity which defendants engaged in what conduct that cause him to suffer severe distress. Indeed, other than whining that he has a bad case of butthurt, he does nothing to establish that he suffered severe distress. The standard is quantified by the intensity, duration, and any physical manifestations of the distress. A lack of productivity or a mental disorder (documented by a mental health professional) is typically required, and, of course, TDPK has no evidence to back up such a claim.