The following excerpt is from James v. Sweeny, CASE No. 1:12-cv-01704-LJO-MJS (PC) (E.D. Cal. 2012):
6. See e.g., Sapp v. Kimbrell, 623 F.3d 813, 826 (9th Cir. 2010) (an exception to exhaustion has been recognized where a prison official renders administrative remedies effectively unavailable.)
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