The following excerpt is from Hamilton v. Armstrong, No. 2:19-cv-0445-EFB P (E.D. Cal. 2019):
1. A prisoner may not avoid incurring a "strike" simply by declining to take advantage of opportunities to amend. Harris v. Mangum, 863 F.3d 1133, 1142-1143 (9th Cir. 2017).
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