The trial court correctly denied this lawyer-defendant’s Anti-SLAPP motion, finding that this suit to collect the agreed price for its services was not based on protected speech.  The fraud and concealment claim brought against the lawyer was for misrepresentations and concealments about the client-buyer’s financial condition which induced plaintiff to enter into the services contract.  Communications at the pre-contract stage were not settlement negotiations, which began only after the services were rendered and not paid for.  The trial court properly awarded sanctions for the frivolous motion, and the Court of Appeal adds another $20,000 in sanctions for the defendant’s frivolous appeal.