Does litigation privilege apply to statements made in a judicial proceeding?

California, United States of America


The following excerpt is from Merlet v. Rizzo, 64 Cal.App.4th 53, 75 Cal.Rptr.2d 83 (Cal. App. 1998):

The litigation privilege applies when statements are "(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) [they have] some connection or logical relation to the action." (Silberg v. Anderson (1990) 50 Cal.3d 205, 212, 266 Cal.Rptr. 638, 786 P.2d 365.) The privilege "extends 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

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