In Vivian v. Labrucherie, 214 Cal. App. 4th 267, 153 Cal. Rptr. 3d 707 (Cal. Ct. App. 2013), Labrucherie's boyfriend, nicknamed "Dodi," sought injunctive relief against her ex-husband, Vivian, a county deputy sheriff. Dodi alleged that Vivian was harassing him by following him in his patrol car and telling law enforcement officials in Dodi's native country that Dodi was being investigated by the sheriff's department. The court granted a TRO. Soon thereafter, Vivian asked the sheriff's department to open an internal affairs investigation into Dodi's allegations. The following month Vivian and Dodi entered into a settlement. Dodi agreed to drop his request for a permanent injunction and he, Vivian, and Labrucherie agreed not to disparage "any other party." Id. at 710. Even though she was not a party, Labrucherie signed the settlement agreement and represented that (with an exception not relevant here) she would be bound by it. A year later, Vivian sued Labrucherie, her mother, and Dodi, alleging among other things that Labrucherie had violated the settlement agreement by making disparaging statements about him to people in the sheriff's office's internal affairs department, during its investigation. Labrucherie moved to dismiss the complaint, arguing the absolute privilege protected her from liability for breaching the non-disparagement agreement. The court denied the motion, and she noted a permitted interlocutory appeal. The appellate court reversed, holding that the absolute litigation privilege insulated Labrucherie from liability for breaching the non-disparagement agreement by means of her communications about Vivian to the sheriff's department. It found that applying the privilege would "further the policies underlying the privilege." Id. at 715. Specifically, in the context of police investigations, that policy is "'to assure utmost freedom of communication between citizens and public authorities whose responsibility it is to investigate and remedy wrongdoing.'" Id. (quoting Williams v. Taylor, 129 Cal. App. 3d 745, 181 Cal. Rptr. 423, 428 (1982). The court observed that the dispute involved "a significant public concern -- a governmental investigation into inappropriate conduct by a police officer -- and that the public purpose is served by application of the privilege here in a way that does not apply to statements made in many other contexts." Id. at 716.