Briggs v. Eden Council for Hope and Opportunity (1999) 19 Cal. 4th 1106 [81 Cal. Rptr. 2d 471, 969 P.2d 564] teaches there is no separate requirement that statements made in legislative, judicial, and similar fora or statements made in connection with issues pending before such fora involve a "public issue." The Briggs court stated: "Clauses (3) and (4) of section 425.16, subdivision (e), concerning statements made in public fora and 'other conduct' implicating speech or petition rights, include an express 'issue of public interest' limitation; clauses (1) and (2), concerning statements made before or in connection with issues under review by official proceedings, contain no such limitation." ( Briggs v. Eden Council for Hope & Opportunity, supra, 19 Cal. 4th at p. 1117.)