California, United States of America
The following excerpt is from In re Pierce, F063915 (Cal. App. 2012):
2. In Mahdavi v. Superior Court (2008) 166 Cal.App.4th 32, the court held that the requirement to seek leave to file an appeal does not apply to a defendant who has been declared a vexatious litigant in unrelated litigation. The court reasoned that an appealing defendant is not filing "'new'" litigation but rather attempting to "'undo'" the results of litigation that had been instituted against him. (Id. at pp. 40-41.)
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