In my opinion, it depends on the starting distance.
In the forum fight, most likely Emma (0.5 km space between the fighters). In comics? Already happened, although Sue was close and took Emma by surprise.
When the Fantastic Four discovered Jean Grey in the cacoon she didn't have her telepathy. She only had telekinesis as Reeds machine damaged Jeans telepathy. So Sues shields blocked her telekinesis.
We should also mention Jean wasn't fighting at her best because he was confused and disoriented when she emerged from her cocoon. She was so out of it, she still thought she had her TP despite the fact that she lost it.
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..even the outer hells are indifferent matters for they bow only to potent and archaic Nodens.