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4460 REVIEW DENIED Attorneys who were appointed as deputy district attorneys and who took the necessary oaths, but for whom the requisite certificates were not filed, are de facto deputy district attorneys and as such are afforded the same absolute immunity as de jure deputy district attorneys; their conduct as deputy district attorneys was not made unlawful by the failure to file certificates, so the SLAPP statute applies to an action against them for malicious prosecution.CitationMILLER v FILTER (Deputy DA) 150 CA4 652 [See: GovC 821.6, 24102; CCP 425.16; Flatley v Mauro 39 C4 299, P/AT 9/06; Amylou R v County 28 CA4 1205, T/AT 11/94]
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