The following excerpt is from Merckens v. F. I. Dupont, Glore Forgan & Co., 514 F.2d 20 (2nd Cir. 1975):
We do not reach the question of the nature of the offense charged in the complaint, although we do note that a complaint drafted by a pro se litigant must be liberally construed in view of his lack of professional sophistication. See Haines v. Kerner, 404 U.S. 519, 520, 92 S.Ct. 594, 30 L.Ed.2d 652 (1972) (per curiam). The defendant's alternative
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