In Friedman v. Knecht (1967) 248 Cal.App.2d 455, the Court held to be afforded protection, the defamatory matter need not be strictly pertinent or relevant to any issue involved in the litigation, but it must have some reference to the subject matter thereof. ( Id. at p. 460.) The Court determined that the right of an attorney engaged in a judicial proceeding and in active pursuit of the objectives of that proceeding, to make defamatory statements related to any issue in that action was absolute. The Court pointed out in the Friedman opinion that language privileged by section 47, subdivision 2, of the Civil Code need not be totally unbridled or unchallengeable. This is because of the availability of court imposed sanctions and, especially in the case of attorneys, the availability of disciplinary actions taken by the state bar. These alternatives achieve the purpose of discouraging acrimonious exchanges between parties or their attorneys, while preserving their right to litigate. As we stated in Friedman, supra: "We are satisfied that in all but an infinitesimal number of cases such sanctions are adequate to curb those who would abuse their privilege and, at the same time, to protect an attorney whom his opponent might be tempted to slander." ( Id. at p. 462.)