Schmid v. County of Sonoma CA1/2
The trial court declared attorney Frear Stephen Schmid (Frear) a vexatious litigant on the ground that he had suffered five adverse determinations in the last seven years in cases he had brought in propria persona (pro per) (Code Civ. Proc., § 391, subd. (b)(1)1) and included a prefiling order barring him from initiating any further litigation in pro per without leave of court. It declined to find his wife, Astrid, a vexatious litigant
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