Aryana

MEMORANDUM *

The litigation privilege of California Civil Code § 47(b) provides in relevant part: “A privileged publication or broadcast is one made: ... [i]n any ... judicial proceeding.” Cal. Civ.Code § 47. The California Supreme Court has determined that 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.” Silberg v. Anderson, 50 Cal.3d 205, 212 , 266 Cal.Rptr. 638 , 786 P.2d 365 (1990). This extends to “any publication required or permitted by law in the course of a judicial proceeding to achieve the objects of the litigation, even though the publication is made outside the courtroom and no function of the court or its officers is involved.” Id. The privilege is absolute and has been broadly applied, regardless of malice. Jacob B. v. County of Shasta, 40 Cal.4th 948, 955 , 56 Cal.Rptr.3d 477 , 154 P.3d 1003 (2007).

We are satisfied that each of the four elements is met in this case. First, the Appellants do not contest that Roossien’s letter was a…