California, United States of America
The following excerpt is from Girard v. Ball, 125 Cal.App.3d 772, 178 Cal.Rptr. 406 (Cal. App. 1981):
It must also appear that the defendant's conduct was unprivileged. (Fletcher v. Western National Life Ins. Co. (1970) 10 Cal.App.3d 376, 394, 89 Cal.Rptr. 78.)
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