Williams v. County of Fresno

I. DISCUSSION

25 Rule 182(d) of the Local Rules of the United States District Court, Eastern District of 26 California provides that an attorney who has appeared on behalf of a client may not withdraw, 27 leaving the client in propria persona, without leave of court. “Withdrawal of an attorney is 28 governed by the Rules of Professional Conduct of the State Bar of California.” Local Rule 182(d). Under those rules, mandatory withdrawal is required as follows: (a) Except as stated in paragraph (c), a lawyer shall not represent a client or, where representation has commenced, shall withdraw from the representation of a client if: (1) the lawyer knows or reasonably should know that the client is bringing an action, conducting a defense, asserting a position in litigation, or taking an appeal, without probable cause and for the purpose of harassing or maliciously injuring any person; 7 (2) the lawyer knows or reasonably should know that the representation will result in violation of these rules or of the State Bar Act; 9 (3) the lawyer’s mental or physical condition renders it …