In Howard v. Drapkin (1990) 222 Cal.App.3d 843, the court held that a psychologist, while acting as a neutral third party in attempting to resolve a family law dispute, was protected from civil suit by common law quasi-judicial immunity, under which California courts have extended absolute immunity to persons other than judges who act in a judicial or quasi-judicial capacity. (Id. at pp. 851-853.) The psychologist in Howard provided alternative dispute resolution services pursuant to a private agreement between the plaintiff and her former husband, "albeit in the shadow of pending litigation." (Id. at p. 855, fn. 6.) Ultimately her status was governed by a court order, but the appellate court pointed out that this fact was not crucial to its conclusion. (Ibid.) Rather, the court held that "the job of third parties such as mediators, conciliators and evaluators involves impartiality and neutrality, as does that of a judge, commissioner or referee; hence, there should be entitlement to the same immunity given others who function as neutrals in an attempt to resolve disputes. In a sense, those persons are similar to a judge who is handling a voluntary or mandatory settlement conference, no matter whether they are: (1) making binding decisions (such as referees acting pursuant to Code Civ. Proc., 638, subd. (1), and arbitrators); (2) making recommendations to the court (such as referees acting under Code Civ. Proc., 639 or mediators acting under Code Civ. Proc., 4607); (3) privately attempting to settle disputes, such as the defendant here. We therefore hold that absolute quasi-judicial immunity is properly extended to these neutral third parties for their conduct in performing dispute resolution services which are connected to the judicial process and involve either (1) the making of binding decisions, (2) the making of findings or recommendations to the court or (3) the arbitration, mediation, conciliation, evaluation or other similar resolution of pending disputes." (Id. at p. 860.)