The trial court properly granted defendants’ Anti-SLAPP motion. Despite plaintiff’s allegation that defendant had engaged in extortion, this case was distinguishable from Flatley v. Mauro (2006) 39 Cal.4th 299 because defendant denied that he had threatened to report plaintiff to the State Bar unless he settled defendant’s client’s suit for refund of an unearned retainer fee. His emails, though contentious, did not connect a threat to file a State Bar complaint with a demand for money. A telephone call recording was inadmissible under Pen. Code 632 as the only exception is for criminal prosecutions for extortion, not civil proceedings for extortion. Hence, the conduct on which the suit was based was protected under CCP 425.16(e). Defendant established a probability of prevailing on the merits by relying on the absolute litigation privilege.