In Fenelon v. Superior Court (1990) 223 Cal. App. 3d 1476 273 Cal. Rptr. 367, the court concluded that reports of potential criminal activity to the police were subject to the qualified privilege, citing case law from other jurisdictions, and reasoning that Williams permitted " 'effective character assassination . . . .' " (223 Cal. App. 3d at p. 1483, quoting Toker v. Pollak (1978) 44 N.Y.2d 211, 222 405 N.Y.S.2d 1, 7, 376 N.E.2d 163, 169.) Subsequently, no reported California case has followed Fenelon. In Fenelon v. Superior Court (1990) 223 Cal. App. 3d 1476, 273 Cal. Rptr. 367, Division One of the Fourth District concluded that knowingly false reports made to the police are not privileged. The court found support for its conclusion in the weight of authority from other jurisdictions and the fear that absolute privilege without the safeguards of quasi-judicial proceedings would facilitate malicious use of law enforcement mechanisms. ( Fenelon, supra, 223 Cal. App. 3d at pp. 1482, fn. 8, 1483.)