The following excerpt is from Springs v. Diaz, Case No. 21cv862-MMA (AGS) (S.D. Cal. 2021):
exceptional circumstances exist where there is cumulative showing of both a likelihood of success on the merits and an inability of the pro se litigant to articulate his claims considering their legal complexity. Palmer v. Valdez, 560 F.3d 965, 970 (9th Cir. 2009).
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