In Dowling v. Zimmerman (2001) 85 Cal.App.4th 1400, 1414, a condominium owner filed an action against the attorney who represented two of his lessees in unlawful detainer and harassment actions. ( Id. at pp. 1406-1407.) The attorney sent a letter to her client's homeowner's association, advising them the safety of all tenants was at risk and referring to the owner's acts of harassment. ( Id. at pp. 1407-1408.) The owner filed suit for defamation, misrepresentation, and infliction of emotional distress. ( Id. at p. 1409.) In relaying the decision of the trial court, the Court of Appeal stated that the trial court found "'the letter would not have been written but for the pending litigation.'" ( Id. at p. 1411.) This statement from the trial court's ruling had no bearing on the resolution of the case on appeal. The attorney's statements regarding the condominium owner's acts of harassment were related to the issue in the lessee's harassment action, leading the Court of Appeal to conclude the attorney's actions arose from statements "'made in connection with an issue under consideration or review by a . . . judicial body' within the meaning of section 425.16, subdivision (e)(2)." (85 Cal.App.4th at p. 1420.) The opinion of the Court of Appeal does not endorse a "but for" analysis in determining whether a statement is "made in connection with an issue under consideration or review" by a judicial body for purposes of section 425.16.