The following excerpt is from Ogle v. Pollard, Case No.: 3:20-cv-1115-LAB(KSC) (S.D. Cal. 2020):
Second, a pro se prisoner's inability to afford an attorney, standing alone, is not enough to show exceptional circumstances. This and other hardships imposed by petitioner's incarceration "are difficulties which any litigant would have in proceeding pro se; they do not indicate exceptional factors." Wood v. Housewright, 900 F.2d 1332, 1335-1336 (9th Cir. 1990).
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