The following excerpt is from Bashor v. Risley, 730 F.2d 1228 (9th Cir. 1984):
The district court found that the petitioner was adequately representing himself and stated that less stringent standards would be applied to his pleadings than to those drafted by lawyers. Haines v. Kerner, 404 U.S. 519, 520, 92 S.Ct. 594, 595, 30 L.Ed.2d 652 (1972) (pro se complaint held to less stringent standards). Although the appellant is over 60 years of age and has no background in the law, he thoroughly presented his issues in the habeas petition and the accompanying memorandum of law. The court acted within its discretion when it determined that the interests of justice did not require appointment of counsel.
3. Change of Venue
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