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1522 REVIEW DENIED Filing an improper lien on the proceeds of a tort claim with knowledge that doing so will interfere with the right of the claimant's attorney to collect his/her fee may result in liability for intentional interference with contract; in the absence of a relationship between the parties, a defendant's non-disclosure does not result in liability for fraud, or for negligent interference with economic advantage; in the absence of conduct that is independently wrongful, there is no liability for intentional interference with prospective advantage.CitationLIMANDRI v JUDKINS (Fee Interference) 52 CA4 326 [See: Heliotis v Schuman 181 CA3 646; PG&E v Bear Stearns 50 C3 1118; Herron v State Farm 56 C2 202; J'Aire v Gregory 24 C3 799; Stolz v Wong 25 CA4 1811, T/AT 7/94; Fifield v Finston 54 C2 632]
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