The following excerpt is from Shabazz v. Giurbino, Case No.: 1:11-cv-01558-DAD-SAB (PC) (E.D. Cal. 2017):
Oxendine, 509 F.2d at 1407; Cevallos v. City of Los Angeles, 914 F.Supp. 379, 385 (C.D. Cal. 1996) (to fairly and adequately represent a class of individuals the plaintiffs must be represented by counsel). "This rule is an outgrowth not only of the belief that a layman, untutored in the law, cannot 'adequately represent' the interests of the members of the 'class,' but also out of the long-standing general prohibition against even attorneys acting as both class representative and counsel for the class." Huddleston v. Duckworth, 97 F.R.D. 512, 514 (N.D. Ind. 1983).
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