California, United States of America
The following excerpt is from Jay v. Mahaffey, G047325 (Cal. App. 2013):
This argument is misplaced. Neither the Lawrences nor the attorneys cite any anti-SLAPP cases in which, for the first time in reply, the moving parties introduced entirely new evidence. They cite cases in which courts have considered evidence in reply, but such evidence was supplemental to evidence submitted in the moving papers, not brand new. In Wong v. Jing (2010) 189 Cal.App.4th 1354 (cited by defendants for the first time in their reply briefs), the court, in dicta, suggested that a reply declaration was sufficient to establish a defendant's lack of liability. There was, however, no explicit evidentiary ruling in that case.
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