Fifth District So Holds.
In Flores v. Georgeson, Case No. F059173 (5th Dist. Jan. 10, 2011) (certified for publication), the Fifth District held that a vexatious litigant does not need to satisfy the CCP § 391.7(a) permission-prefiling requirement when the litigant is represented by counsel in a case.
The 3-0 decision was penned by Justice Detjen.