fied privilege", FJA Brf. at 10-11, should be summarily rejected. AFTC cites Wade, John H., On Frivolous Litigation: A Study of Tort Liability and Procedural Sanctions, 14 Hofstra L.Rev. 433, 451 (1986) for the inventive proposition that "some scholars" believe that the tort of malicious prosecution "with its extr