The following excerpt is from Quinn v. Dowbak, No. 2:17-cv-0992-MCE-EFB P (E.D. Cal. 2018):
ability of the plaintiff to articulate his claims pro se in light of the complexity of the legal issues involved. Palmer v. Valdez, 560 F.3d 965, 970 (9th Cir. 2009). Having considered those factors, the court finds there are no exceptional circumstances in this case.
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