Defendants may not seek dismissal of action filed by vexatious litigant who filed litigation through counsel but lost representation while action was pending. Joseph L. Shalant v. Thomas V. Girardi, (No. S182629 California Supreme Court, June 23, 2011).
This case stands for the proposition that a vexatious litigant will not be found to violate a prefiling order under California Code of Civil Procedure Section 391 if the action was filed through counsel, even if the action is continued in pro per. California Code of Civil Procedure Section 391.7 prohibits a vexatious litigant from filing any new litigation in pro per in the courts of California without the approval of a presiding judge of the court in which the action is filed.
Adjmediator's Blog 