The California Court of Appeal has held that “under a long-standing common law rule of procedure, a corporation, unlike a natural person, cannot represent itself before courts of record in propria persona, nor can it represent itself through a corporate officer, director or other employee who is not an attorney.” CLD Construction, Inc. v. City of San Ramon, 120 Cal. App. 4th 1141, 1146 (Cal. App. 1st Dist. 2004). Rather, “[i]t must be represented by licensed counsel in proceedings before courts of record.” Id., citing Caressa Camille, Inc. v. Alcoholic Beverage Control Appeals Bd. 99 Cal.App.4th 1094, 1101–1103 (2002).
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