The following excerpt is from Richards v. Harper, 864 F.2d 85 (9th Cir. 1988):
Richards failed to demonstrate the exceptional circumstances necessary for appointment of counsel. A finding of exceptional circumstances requires an evaluation of both "the likelihood of success on the merits and the ability of the petitioner to articulate [her] claims pro se in light of the complexity of the legal issues involved." Weygandt v. Look, 718 F.2d 952, 954 (9th Cir.1983).
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