California, United States of America
The following excerpt is from Olsen v. Harbison, 10 Cal. Daily Op. Serv. 16, 041, 119 Cal.Rptr.3d 460, 191 Cal.App.4th 325 (Cal. App. 2010):
This case is unlike others relied upon by plaintiff, in which the challenged statements were made by someone who was a complete stranger to the litigation. For example, in LiMandri v. Judkins (1997) 52 Cal.App.4th 326, 60 Cal.Rptr.2d 539, the litigation privilege did not apply when a third party filed a notice of lien in ongoing litigation. The court held, "A stranger to a civil action does not become a 'litigant or other participant' in the action merely by filing a notice lien against any judgment or settlement proceeds the plaintiff might realize in the action." ( Id. at p. 345, 60 Cal.Rptr.2d 539.)
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