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4042 A citizen's arrest is noncommunicative conduct and is therefore not protected by the Litigation Privilege; defendant's request that police officers eject plaintiff from defendant's store does not qualify as a report to authorities designed to induce an official investigation and therefore is not protected by the Litigation Privilege.CitationBUCHANAN v MAXFIELD (Unfortunate Shopper) 130 CA4 418 [See: CivC 47; Rubin v Green 4 C4 1187, T/AT 5/93; Hagberg v CA Federal Bank 32 C4 39, T/AT 2/04; Wang v Hartunian 111 CA4 744, P/AT 9/03]
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