Does litigation privilege apply in a medical malpractice action?

⁴ Other cases relied on by plaintiff are also distinguishable in that their holdings are highly fact-specific. For example, in Rickley v. Goodfriend (2013) 212 Cal.App.4th 1136, 151 Cal.Rptr.3d 683, the appellate court held that the litigation privilege did not protect attorney-defendants' communications or conduct that interfered with a court-ordered remediation plan because the conduct had the intended effect of actively assisting their clients in continuing a nuisance, involved nonparticipants to the litigation, and did not constitute an attempt to achieve the objects of the litigation. (Id. at p. 1148, 151 Cal.Rptr.3d 683.) Plaintiff also cites to cases holding that the litigation privilege does not apply to legal malpractice actions. Here, the allegations do not concern claims brought by a former client against his or her attorney.