In O'Keefe v. Kompa (2000) 84 Cal. App. 4th 130, the plaintiff sued for abuse of process after the defendants attempted to enforce a judgment entered against the plaintiff in another action while that action was on appeal. O'Keefe, supra, 84 Cal. App. 4th at page 132. The trial court sustained the defendants' demurrer without leave to amend; the appellate court affirmed, holding that the enforcement efforts (levying on a bank account and filing an abstract of judgment) were privileged "extensions of the judicial process" which "were logically and legally related to the realization of a litigation objective--that is, collection of a judgment." Plaintiff O'Keefe complained that the levy on his bank account constituted an abuse of process. And similarly, O'Keefe suggested that the filed abstract of judgment was fraudulent. The appellate court rejected these claims noting that, for policy reasons, even an otherwise qualifying fraudulent act is privileged under section 47(b). The court added: "The conclusion that defendants' actions were privileged (even if, as alleged, wrongful and harmful) necessarily means plaintiff has no tort remedy against them." O'Keefe, supra, 84 Cal. App. 4th at page 135. In O'Keefe, the court acknowledged that the plaintiff could have posted an undertaking or sought a writ of supersedeas to thwart the enforcement efforts. O'Keefe, supra, 84 Cal. App. 4th at pages 135-136.