In People ex rel. 20th Century Ins. Co. v. Building Permit Consultants, Inc. (2000) 86 Cal.App.4th 280, the issue was whether the defendant's conduct qualified for protection under the anti-SLAPP statute. (20th Century, supra, 86 Cal.App.4th at pp. 283-285.) There, the defendant was sued for preparing false insurance damage estimates for victims of the Northridge earthquake, estimates that in some cases made their way as evidence into judicial proceedings. The court concluded that because the estimates were not prepared "before," or "in connection with an issue under consideration or review by a legislative, executive, or judicial body, or any other official proceeding authorized by law" ( 425.16, subd. (e)), that conduct was not "in furtherance of the defendant's right of petition or free speech" ( 425.16, subd. (b)(1)) and, therefore, did not qualify for protection under the anti-SLAPP statute. (20th Century, supra, 86 Cal.App.4th at p. 285.)