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Case 18-2868, Document 287, 08/09/2019, 2628251, Page72 of 76 association was a party). Giuffre contends that “there was no statement made by anyone before the commencement of litigation because litigation never commenced.” See Pl.’s Opp’n at 42. Here, the communication at issue was sent to members of the media, and no litigation took place between Maxwell and the media recipients of the Press Release. However, the pre-litigation privilege is not limited to statements between parties and their lawyers. “While the communications at issue in Front were among lawyers and potential parties, the New York Court of Appeals did not explicitly require the recipient of the challenged statements to be a lawyer or potential party.” Feist v. Paxfire, Inc., No. 11 CIV. 5436 (LGS), 2017 WL 177652, at *5 (S.D.N.Y. Jan. 17, 2017); see Front, 28 N.E.3d at 16-17. The Second Circuit “summarily rejected this interpretation when it applied Front to an attorney’s communications to the press.” See Tacopina v. O'Keeffe, 645 F. App’x 7, 8 (2d Cir. 2016) (“Even crediting [the plaintiff]’s allegation that [the attorney] shared the affidavit with the Daily News before filing it in court, Tacopina has still not sustained his burden of showing that the statements were not pertinent to a good faith anticipated litigation.”). 72