1145 Actions arising from statements by defendant on public issues are subject to a special motion to strike under the anti-SLAPP statute, even though the statements were not made publicly.
AVERILL v SUPERIOR COURT (Women's Shelter) 42 CA4 1170 [See: CCP 425.16; Dixon v Superior Court 30 CA4 733, T/AT 1/95; Wilcox v Superior Court 27 CA4 809, T/AT 9/94]
No guarantees.
Always check current status of cases before citing them.