(1993). This privilege has been given an “expansive reach” by California courts, as recognized by the California Supreme Court. See Rubin, 4 Cal.4th at 1194, 17 Cal.Rptr.2d 828, 847 P.2d 1044. This privilege affords absolute immunity against tort liability arising out of such a communication, regardless of attempts by the “plaintiff’ to “plead around” this “absolute barrier.” See id. at 1201-02, 17 Cal.Rptr.2d 828, 847 P.2d 1044. Thus, the immunity applies regardless of the particular label given to the cause of action (e.g., unfair competition). Section 47(b) protects participants in judicial proceedings from derivative tort actions based on communications in or regarding the judicial proceeding. See Dove Audio, Inc. v. Rosenfeld, 47 Cal.App.4th 777, 781-83, 54 Cal.Rptr.2d 830 (1996) (<HOLDING>). A “communication[ ] preparatory to or in
holding that letter to possible coclaimants seeking support for filing of suit was covered by the privilege recognizing privilege holding that voluntary testimony by spouse is not covered by husbandwife privilege holding that documents reflecting the department of educations review of a universitys compliance with title iv were covered by the privilege and rejecting the argument that a specific policy judgment is necessary for the privilege to apply because the privilege servesto protect the processes by which governmental decisions as well as policies are formulated holding that the initial disclosure of a crime to one spouses without more is covered by the marital communications privilege