California, United States of America
The following excerpt is from Schiffman v. Knoll, B286311 (Cal. App. 2019):
faith and under serious consideration"]; Kenne v. Stennis (2014) 230 Cal.App.4th 953, 965 ["[b]ecause Civil Code section 47, subdivision (b) protects any statements or writings that have 'some relation' to a lawsuit, communications made both during and in anticipation of litigation are covered by the statute"].)
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