What is the test for appointing counsel in a civil case?

To determine whether to appoint counsel in a civil case, a district court should first consider whether the indigent litigant's position is likely to be of substance. Hodge v. Police Officers, 802 F.2d 58, 60-61 (2d Cir. 1986). If the district court determines that "threshold requirement" has been met, it should then consider factors including the litigant's ability to investigate his claims, the litigant's ability to present the case, the complexity of the legal issues, and "any special reason

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