Is a plaintiff's claim for wrongful death privileged?

[189 Cal.App.3d 775] There are cases which consider whether all allegations in a complaint are necessarily privileged. In Umansky v. Urquhart (1978) 84 Cal.App.3d 368, 148 Cal.Rptr. 547 (cited in the trial court, but not on appeal), a doctor complained that the attorneys in the underlying action presented a wrongful death complaint which impermissibly sought punitive damages from him. After the punitive damages claim was removed by stipulation, he brought suit, alleging the claim was made to embarrass him and injure his reputation and to pressure him into settlement. (Id., at p. 370, 148 Cal.Rptr. 547.) The court found the punitive damages claim privileged under a liberal construction of the privilege, reasoning it was permissible for lawyers to challenge the existing state of the law, as such a claim would have done. (Id., at pp. 371, 372, 148 Cal.Rptr. 547.)