The following excerpt is from Smith v. Allison, Case No. 1:10-cv-01814-LJO-JLT (PC) (E.D. Cal. 2014):
A plaintiff may proceed on new cognizable claims stated in an amended complaint if his administrative remedies were exhausted after the filing of the original complaint, but prior to the filing of the amended complaint. Rhodes v. Robinson, 621 F.3d 1002, 1003 (9th Cir. 2010). At
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