[brief] Litigation privilege applies to communications or conduct: (1) made in judicial or quasi-judicial proceedings; (2) by litigants or other participants authorized by law; (3) to achieve the objects of the litigation; and (4) that have some connection or logical relation to the action.  Hawkins v. Harris, 141 N.J. 207 (1995).  As the [...] argued with chilling vigor, fraudulent concealment is, in their mind, conduct to achieve the objects of the litigation and that has some connection or logical relation to the action.  Shockingly and appallingly, the Trial Court failed to reject this argument.  However, Plaintiffs maintain – and hope this is not a controversial idea – that fraudulent concealment is not an acceptable tool in the litigation toolbox.  Indeed, for the Trial Court to fail to reject the argument that fraudulent concealment is contemplated by the litigation privilege requires that fraudulent concealment be accepted as permissible to achieve the objects of a litigation.  Plaintiffs insist, in the name of the integrity of our judicial system, and in accordance with the clear, unreversed holding of Viviano v. CBS, Inc., 251 N.J. Super. 113 (1991), that such an assertion is blatantly incorrect.  In Viviano, the Court held that “Immunizing the willful destruction or concealment of evidence would not further the policy of encouraging testimonial candor. ”  The Court in Viviano at 127, goes on to explain:  Destruction [or concealment] of evidence known to be relevant to pending litigation violates the spirit of liberal discovery.  Intentional destruction [or concealment] of evidence manifests a shocking disregard for orderly judicial procedures and offends traditional notions of fair play.  Consequently, recognizing the defendants’ liability for wilfully concealing the Brand memorandum is not inconsistent with either the letter or the rationale of New Jersey’s policy of affording immunity to testimony given during the course of judicial proceedings.  According to the [...], the Viviano Court should have condoned fraudulent concealment and granted attorneys absolute immunity to fraudulently conceal evidence in litigation, presumably so that the [...] could continue to implement it as a staple of their litigation strategy.  Thankfully, however, despite the [...]’ disdain for the Viviano decision and the Trial Court’s erroneous failure to reject the [...]’ argument, Viviano remains good law for over thirty-one years and counting.  Despite the Trial Court’s erroneous failure to reject the argument that litigation privilege barred Plaintiffs’ claims, there is no case law in the State of New Jersey which has extended litigation immunity to fraudulent concealment.  Indeed, there is case law which establishes the exact opposite.  As is self-evident in the holding of Viviano, there is no litigation immunity from claims of fraudulent concealment during the course of a litigation.  Even basic reason and logic would lead to such a conclusion, since the cause of action of fraudulent concealment would cease to exist if this were true, as fraudulent concealment necessarily takes place during litigation.  The Trial Court’s failure to reject the [...]’ litigation privilege argument stands for the outrageous proposition that attorneys may fraudulently conceal evidence with absolute immunity.  Fortunately, that day has not yet come, and the Trial Court did not have authority to reverse Viviano.  Accordingly, the legal malpractice claims against the [...] should not have been dismissed pursuant to the litigation privilege.