§§ 22:1, 22:17, pp. 511, 525.) Dubow’s September 12 letter is a typical example of such a missive. For the above reasons, the privilege to defame in the course of judicial proceedings is not limited to statements during trial but can extend, notwithstanding the phrasing of the statute, to steps taken prior thereto. (See 4 Witkin, Summary of Cal. Law (8th ed. 1974) Torts, § 297, pp. 2567-2568; Annot., Defamation—Pretrial Procedures (1969) 23 A.L.R. 3d 1172, 1174. See also Johnston v. Cartwright (8th Cir. 1966) 355 F.2d 32, 37 (applying similar Iowa privilege to communication of lawyer prior to commencement of lawsuit but where “[a]ll signs pointed to incipient-litigation and to a necessity for protective action”).) (Cf. Martin v. Kearney, 51 Cal.App.3d 309, 311 [124 Cal.Rptr. 281] (<HOLDING>); Frank Pisano & Associates v. Taggart, 29
holding absolutely privileged a communication to an administrative agency designed to prompt action by that agency holding that a draft of a proposed letter from an area director of a government agency to a municipal administrative agency was properly excluded because it did not represent an agency finding holding demand letter written prior to and during litigation absolutely privileged holding that defamation claim fails because communication by employer to dc office of employment services is absolutely privileged  holding that the power of any administrative agency to reconsider its final decision exists only where the statutory provisions creating the agency indicate a legislative intent to permit the agency to carry into effect such power