Following the prior decision of Flatley v. Mauro, the California Court of Appeal in Miguel Mendoza v. Reed K. Hamzeh finds that a demand letter from an attorney which threatens criminal prosecution is not protected under the anti-SLAPP statute. Of interest, the court held that the facts need not be as egregious as those in Flatley; it is enough that the conduct amounts to extortion. All that is needed for extortion is a demand for money coupled with a threat of criminal action. That is true even where the person would be free to report the crime.
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