What is the threshold requirement for a plaintiff to seek counsel in a personal injury case?

"threshold requirement" has been met, a court should consider secondary factors, such as "the indigent's ability to investigate the crucial facts, . . . the indigent's ability to present the case, the complexity of the legal issues and any special reason in that case why appointment of counsel would be more likely to lead to a just determination." Id. at 61-62. We have rejected a policy of appointing counsel only after a plaintiff's claim has survived a dispositive motion. Hendricks v. Coughlin, 114 F.3d 390, 392-93 (2d Cir. 1997).