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GHP Horwath, P.C. v. Kazazian.

2024 CO 8. No. 23SA146. Right of Access—Supervisory Power of the Court—Injunction Against Self-Representation.

February 20, 2024


The Supreme Court made the rule to show cause absolute and enjoined Kazazian, whether acting individually or on behalf of another entity, from proceeding pro se as a proponent of a claim (e.g., as plaintiff, third-party claimant, cross-claimant, or counterclaimant) in any present or future litigation in the state courts of Colorado. While every person has an undisputed right of access to Colorado courts, that right may not be abused, and must yield to the principle that right and justice should be administered without sale, denial, or delay. When a pro se litigant hampers the efficient administration of justice to an intolerable degree, the Court has a duty to stop the abuse with an injunction. The Court enjoined Kazazian because it found her actions rose to the level of being intolerable.

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