The following excerpt is from Klingele v. Eikenberry, 849 F.2d 409 (9th Cir. 1988):
This circuit has approved the Hudson rule and discussed the particular difficulties faced by incarcerated pro per litigants in Jacobsen v. Filler, 790 F.2d 1362, 1364 & n. 4 (9th Cir.1986) (declining to extend rule to pro se nonprisoners).
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