Does the attached pleading requirement apply to a motion to set aside the anti-SLAPP order?

This conclusion is not simply the application of technical requirements to trip up a self-representing litigant. Rather, requiring Madhu to substantially comply with the attached-pleading requirement goes to the fundamental question of whether she could have presented an opposition that had merit and, thus, justified further proceedings in this lawsuit. Presenting a meritorious opposition is a difficult task when a plaintiff brings a lawsuit alleging the defendant committed wrongs in earlier litigation because protected activity includes any written or oral statement made (1) before a judicial proceeding or (2) in connection with an issue under consideration or review by a judicial body. ( 425.16, subd. (e)(1), (2).) It also includes "any other conduct in furtherance of the exercise of the constitutional right of petition." ( 425.16, subd. (e)(4).) On appeal, Madhu claims ex-husband's acts and omissions committed in connection with the marital dissolution and child support litigation are not protected because illegal conduct is not protected. (See Flatley v. Mauro (2006) 39 Cal.4th 299, 317.) However, the Flatley exception is narrowit applies only where "the defendant concedes the illegality of its conduct or the illegality is conclusively shown by the evidence." (Id. at p. 316.) Here, the papers submitted with Madhu's motion to set aside the anti-SLAPP order and her appellate brief have not acknowledged the narrowness of the Flatley exception and demonstrated illegality was conceded or conclusively shown by the evidence.