Can a plaintiff recover attorney fees for time spent litigating this action?

While plaintiff, a pro se litigant, may not recover attorney fees for time spent litigating this action (see 42 U.S.C. 1988; Gonzalez v. Kangas, 814 F.2d 1411, 1412 (9th Cir. 1987)), defendants have provided the court with no authority holding that a person whose litigation efforts have been unconstitutionally frustrated in an underlying action may not obtain compensation for those efforts as a measure of damages in a 1983 action premised on denial of access to courts. In fact, the few courts to have addressed the issue have rejected defendants'

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