Is there a special relationship between a witness in a police investigation and the police department?

Plaintiff has not cited any authority that a special relationship exists between a witness in a police investigation and the police department. Indeed, for tort purposes, police officers are held not to be a special relationship with witnesses. Zelig v. County of Los Angeles, 27 Cal.4th 1112, 1129 (2002) (county was not liable for failing to protect a litigant from a violent attack by her husband in a courthouse because there was no such special relationship). Disclosing private information of a witness may violate certain other statutory protections, see infra, but such disclosure has not been held to be "extreme and outrageous," abusing a special relationship, to support a common law tort claim. Accordingly, summary adjudication is appropriate for this cause of action.