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4481 In an action against an accountant based on the claim that in preparing his expert testimony the accountant failed to use generally accepted accounting practices and properly review documentation, the gravamen was defendant's testimony in litigation, so noncommuncative conduct in which he engaged as part of the preparation of that testimony is protected by the Litigation Privilege.
RAMALINGAM v THOMPSON (Accountant's Testimony) 151 CA4 491 [See: CivC 47; Moore v Conliffe 7 C4 634, T/AT 6/94; Jacob B v County 40 C4 948, T/AT 4/06; Rusheen v Cohen 37 C4 1048, T/AT 3/06]
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