There are multiple prongs to the tort and all of them have to be fulfilled. A reasonable jury cannot conclude that leaking the memo to the media is outrageous c

There are multiple prongs to the tort and all of them have to be fulfilled. A reasonable jury cannot conclude that leaking the memo to the media is outrageous conduct beyond all the standards of civilised society. It no longer matters if the defendant acted intentionally; the claim fails and must be dismissed.