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the Court in Clemens v. McNamee, held that communications to government agencies as part of legislative, judicial, or quasi-judicial proceedings are entitled to absolute immunity

the Court in Clemens v. McNamee, held that communications to government agencies as part of legislative, judicial, or quasi-judicial proceedings are entitled to absolute immunity so long as they are made as part of an ongoing proceeding, they are not unsolicited and they are made to an agency whose findings need not be approved or ratified by another agency

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