4004 REVIEW DENIED Defamatory statements made during the course of an administrative agency's official investigation of alleged improprieties are privileged; liability for intentional infliction of emotional distress requires evidence that defendant's conduct exceeded all bounds usually tolerated in a civilized community; in an administrative proceeding under an Insurance Code section authorizing the Insurance Commissioner to investigate tort claims against an insolvent insurer, the Commissioner did not abuse discretion in rejecting a claim of fraudulent inducement of an employment contract based on conclusory statements by the claimant that were unsupported by a detailed description of the alleged fraud, the circumstances of the hiring, or the content, maker, or recipient of any specific misrepresentation; the Insurance Commissioner did not abuse discretion in rejecting a claim of constructive discharge based on the allegation that the claimant was ordered to ignore irregularities on pain of possible termination, unsupported by any showing of how or whether that warning affected the claimant's working conditions.

GARAMENDI v GOLDEN EAGLE (Insurance Improprieties) 128 CA4 452 [See: InsC 1032, 1021; CivC 47(b); Lazar v Superior Court 12 C4 631, T/AT 2/96; Turner v Anheuser 7 C4 1238, T/AT 8/94; Hagberg v CA Federal Bank 32 C4 39, T/AT 2/04; Potter v Firestone 6 C4 965, T/AT 2/94]