cious Prosecution Does Not Carry a Uniquely Onerous Burden for the Plaintiff. 6 The Tort of Malicious Prosecution is Disfavored and at War with the Litigation Privilege's Underlying Policies. 9 The Lesson to be Learned from California. 12 CONCLUSION 15 CERTIFICATE OF SERVICE. 16 CERTIFICATE OF COMPLIANCE. 17 i EFTA00610601