The following excerpt is from Vandergriff v. Thomas, 103 F.3d 143 (9th Cir. 1996):
We have long held that a pro se litigant must be given notice of his complaint's deficiencies and leave to amend the complaint. See Noll v. Carlson, 809 F.2d 1446, 1448 (9th Cir.1987).
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