The following excerpt is from In re Lawrence And Julie Salander, 450 B.R. 37 (Bankr. S.D.N.Y. 2011):
McDonald v. Head Criminal Court Supervisor Officer, 850 F.2d 121, 124 (2d Cir.1988). ([W]hile pro se litigants may in general deserve more lenient treatment than those represented by counsel, all litigants, including pro ses, have an obligation to comply with court orders. When they flout that obligation they, like all litigants, must suffer the consequences of their actions.).
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