The following excerpt is from Campbell v. United States, No. 12-3845-cv (2nd Cir. 2013):
We review a district court's grant of a motion to dismiss a complaint pursuant to Rule 12(b)(1) de novo, accepting as true factual allegations made in the complaint, and drawing all reasonable inferences in favor of the plaintiff. See Town of Babylon v. Fed. Hous. Fin. Agency, 699 F.3d 221, 227 (2d Cir. 2012). "[A] court is ordinarily obligated to afford special solicitude to pro se litigants" based on "[t]he rationale . . . that a pro se litigant generally lacks both legal training and experience." Tracy v. Freshwater, 623 F.3d 90, 101 (2d Cir. 2010). However, as "a lawyer representing himself[,] [Campbell] receives no such solicitude at all." Id. at 102.
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