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3850 The litigation privilege (Civil Code section 47) protects statements made to the authorities for the purpose of procuring an arrest, but does not protect the noncommunicative act of making a citizen's arrest; persons liable as co-conspirators may be held jointly and severally liable for noneconomic damages.CitationKESMODEL v RAND (Citizen's Arrest) 119 CA4 1128 [See: CivC 47; Hagberg v Cal Fed 32 C4 350, T/AT 2/04; Wang v Hartunian 111 CA4 744, P/AT 9/03; Hamburg v WalMart 116 CA4 497, T/AT 4/04]
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