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4190 If the gravamen of a cause of action is based on a communicative act that is covered by the Litigation Privilege, the privilege extends to noncommunicative acts necessarily related to it; in an abuse of process claim based on the filing of allegedly false declarations to obtain a default judgment, postjudgment enforcement efforts are protected by the Litigation Privilege.CitationRUSHEEN v COHEN (Post-J Enforcement) 37 C4 1048 [See: CCP 425.16; CivC 47; Rubin v Green 4 C4 1187, T/AT 5/93; Kimmel v Goland 51 C3 202; Drum v Bleau 107 CA4 1009, T/AT 5/03; Brown v Kennard 94 CA4 40, T/AT 1/02]
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