4658 In an action arising from a landlord's filing of a wrongful detainer, the Litigation Privilege prevents plaintiff from making out a prima facie case; the Litigation Privilege applies to threats by the representative of a landlord who has filed an unlawful detainer against the tenant regarding the legal effects of the tenant's failure to evacuate; misrepresentations by the landlord that led to the tenant's occupancy occurred before the unlawful detainer was filed and are unrelated to it, so they are not covered by the Litigation Privilege; in deciding the landlord's SLAPP motion, the tenant's causes of action arising from the unlawful detainer and in which the Litigation Privilege prevents the tenant from making out a prima facie case should be stricken.Citation1100 PARK LANE ASSOCIATES v FELDMAN (Unlawful Detainer) 160 CA4 1467 [See: CCP 425.16; CivC 47; Action Apartment v City of SM 41 C4 1232 ]
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