What is the test for a request for voluntary assistance of counsel in a personal injury case?

The test for exceptional circumstances requires the court to evaluate the plaintiff's likelihood of success on the merits and the ability of the plaintiff to articulate his claims pro se in light of the complexity of the legal issues involved. See Wilborn v. Escalderon, 789 F.2d 1328, 1331 (9th Cir. 1986). Circumstances common to most prisoners, such as lack of legal education, do not establish exceptional circumstances that would warrant a request for voluntary assistance of counsel.