California, United States of America
The following excerpt is from Illingworth v. Garton, D066323 (Cal. App. 2015):
2. We note defendant's anti-SLAPP motion stated he was moving to strike plaintiff's "complaint" and "all causes of action contained therein." However, we note the trial court in its order denying that motion did so only on plaintiff's defamation cause of action. In light of our decision in this case, we need not decide in this appeal whether the remaining causes of action in plaintiff's complaint are derivative of the defamation cause of action. (See Lee v. Fick (2005) 135 Cal.App.4th 89, 98 [concluding slander and interference claims were derivative of libel claim and thus were also subject to the anti-SLAPP statute].) We note, however, that in his moving papers filed in this court, defendant focused exclusively on his defamation cause of action and/or the defenses thereto, without regard to any of the other five causes of action in plaintiff's complaint.
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