California, United States of America
The following excerpt is from Wilton v. Mountain Wood Homeowners Assn., 18 Cal.App.4th 565, 22 Cal.Rptr.2d 471 (Cal. App. 1993):
[18 Cal.App.4th 569] If the publication is made by a party to a judicial proceeding, that publication is absolutely privileged and cannot be the subject of a disparagement suit. (Silberg v. Anderson (1990) 50 Cal.3d 205, 212, 266 Cal.Rptr. 638, 786 P.2d 365.) To be protected by this privilege, the statements must be "(1) made in judicial or quasi-judicial proceedings; (2) by litigants or other participants authorized by law; (3) to achieve the objects of the litigation; and (4) [have] some connection or logical relation to the action." (Ibid.)
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