Does litigation privilege apply to communications between plaintiffs and defendants?

all tort actions except malicious prosecution claims. (Ibid.) The litigation privilege "applies to any communication (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) that have some connection or logical relation to the action." (Id. at p. 212.) Whether a plaintiff has made a prima facie showing of his ability to overcome the litigation privilege is "a factual question that will require evaluation of plaintiffs' proffered evidence . . . ." (Birkner v. Lam (2007) 156 Cal.App.4th 275, 286.)