The following excerpt is from Flournoy v. Maness, No. 2:11-cv-2844-KJM-EFB P (E.D. Cal. 2014):
Pro se pleadings are held to a less stringent standard than those drafted by lawyers. Haines v. Kerner, 404 U.S. 519, 520-21 (1972). Unless it is clear that no amendment can cure its defects, a pro se litigant is entitled to notice and an opportunity to amend the complaint before
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