The Second Appellate District finally eliminates the confusion, holding in Marriage of Perow & Uzelac (2019) 31 Cal.App.5th 984, that a responding party’s request for sanction-based attorney fees under section 271 is not an impermissible request for alternative relief on different issues. The court explains that the Family Code, Section 213 restrictions on seeking affirmative relief on issues different than those raised in the moving papers are designed to keep the proceeding limited in scope to the “message” raised by the moving papers. By contrast, when the responding party is seeking Family Code, section 271 sanctions to redress the moving party’s conduct in litigating his/her motion, the sanctions request does not fall outside the scope of the moving party’s “message”. The sanctions request is properly responsive to the conduct of the movant and is therefore a permissible “attack on the messenger, not on his message.” (Id. at p. 991.)