Pre-litigation communications fall within the absolute litigation privilege only when made in anticipation of litigation contemplated in good faith and under serious consideration. Here, a lawyer’s letter on behalf of an entity that plaintiff claimed owed it money was not made in the context of seriously contemplated litigation. The lawyer and its client didn’t contemplate suing. The other party had not threatened suit, but only wrote a third party asking it for help in obtaining the money that the plaintiff thought it was owed. Another cause of action claimed defendant law firm had aided and abetted its client’s fraud even before and not in connection with the lawyer’s letter, which merely was an attempted coverup of the prior aiding and abetting. The litigation privilege did not apply.