and is exempt from liability for defamation. See Hill, 776 A.2d at 840 (noting that the litigation privilege “covers statements made during settlement negotiations or while engaged in a private conference with an attorney regarding litigation”). Bell’s November 1, 2007 letter to the New York Committee on Professional Standards was absolutely privileged. The Supreme Court of New Jersey has adopted a rule granting an ethics complainant immunity from suit by the lawyer against whom the complaint was made. See In re Hearing on Immunity for Ethics Complainants, 96 N.J. 669, 477 A.2d 339, 341-44 (1984) (invalidating statute allowing attorney to bring malicious prosecution action against ethics complainant); see also Toker v. Pollak, 44 N.Y.2d 211, 405 N.Y.S.2d 1, 376 N.E.2d 163, 168 (1978) (<HOLDING>). Bell’s November 1, 2007 letter to the New
recognizing absolute immunity from suit in new york for filing a complaint before a grievance committee of a bar association holding bjecause immunity from liability constitutes an affirmative defense not a jurisdictional bar only immunity from suit is properly before us today holding that prosecutors have absolute immunity holding by a 21 vote that an ohio probate judge was entitled to absolute immunity for filing a criminal complaint recognizing that absolute immunity is immunity from charges of either constitutional or statutory violations