The following excerpt is from Brown v. Continental Can Co., 765 F.2d 810 (9th Cir. 1985):
Section 2000e-5(f)(1) provides that upon application of the complainant, the court may appoint counsel in employment discrimination cases "in such circumstances as the court may deem just." The decision of the district court is subject to review only for an abuse of discretion. Bradshaw v. Zoological Society of San Diego, 662 F.2d 1301, 1318 (9th Cir.1981). In exercising its discretion the court is required to assess: (1) the complainant's financial resources; (2) the efforts made by the complainant to secure counsel; and (3) whether the complainant's claim has merit. Id.
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