In Shekhter v. Financial Indemnity Co. (2001) 89 Cal.App.4th 141, the Court discussed the situation when a plaintiff sues both the lawyer and client for litigation-related conduct in an underlying lawsuit. We recognized that the application of a section 425.16 special motion to strike a complaint naming an attorney and a client may not be the same. The Court noted: "As to whether Mr. Kass and the Manning law firm, as the lawyers for Financial and Allstate, had standing to bring the special motion to strike, this issue is resolved by the language of section 425.16 subdivision (b)(1) which states in pertinent part: 'A cause of action against a person arising from any act of that person in furtherance of the person's right of petition or free speech under the United States or California Constitution in connection with a public issue shall be subject to a special motion to strike . . . .' As can be noted, the italicized language requires that the defendant . . . be the individual who is or was being sued for exercise of 'that person's' right of petition or free expression." ( Shekhter v. Financial Indemnity Co., supra, 89 Cal.App.4th at p. 152.) In Shekhter, we held that the attorney and his law firm were entitled to specially move to strike pursuant to section 425.16. In Shekhter, in addition to representing several clients, insurance companies, in another lawsuit, the attorney and his law firm exercised free expression rights independent of their representation in the underlying litigation. In Shekhter, we noted that the cross-complaint alleged tort claims based upon contact by the attorney and the law firm with broadcasting outlets and a "'nationally syndicated journalist. '" ( Id. at p. 153.) In Shekhter, the Court concluded that the lawyer and his law firm were exercising their own free expression rights when communicating with journalists outside of the courtroom. But we did not resolve the question of whether an attorney could secure the benefit of section 425.16 while merely representing a client's interests in litigation.