From Acolatse v. Astrue, 2011 U.S. Dist. LEXIS 4835 (N.D. Cal. Jan. 12, 2011):
Kalagian's claim that continuing to pursue this matter on behalf of Acolatse may subject him to sanctions under Rule 11 of the Federal Rules of Civil Procedure qualifies as a permissible reason for withdrawal. See e.g., Collins v. Astrue, No. 1:08-CV-00476-SMS, 2009 WL 179783 (E.D. Cal. Jan. 26, 2009) (granting a motion to withdraw on similar grounds in a Social Security appeal).
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