24Beverly W. Snukals and Glen H. Sturtevant Jr., “Pro Se Litigation: Best Practices from a Judge’s Perspective,” University of Richmond Law Review 42 (2) (2007) [LINK]; United States District Court, District of Minnesota, and the Federal Bar Association, Minnesota Chapter, The Pro Se Project (Minneapolis: United States District Court, District of Minnesota, and Federal Bar Association, Minnesota Chapter, 2011), 2 [LINK]; and Commonwealth of Massachusetts, The Trial Court, Probate and Family Court Department, Pro Se Litigants: The Challenge of the Future (Boston: Commonwealth of Massachusetts, 1997), 16 [LINK].

Don’t you think consistency requires that you should either say ‘I have confidence in all men,’ and take down your notification; or else say, ‘I suspect all men,’ and keep it up."...To say that strangers are not to be trusted, does not that imply something like saying that mankind is not to be trusted; for the mass of mankind, are they not necessarily strangers to each individual man?
Experimenters remained blind to participants’ affirmation condition during the experimental session, following procedures as in Study 1. Following procedures from recent self-compassion research (Leary et al., 2007, Study 4), participants arrived at the lab one-at-a-time for a study they believed explored the influence of adults’ moods on story telling. After providing written informed consent, participants completed individual difference baseline measures, including trait self-compassion (Neff, 2003b; Raes et al., 2011). Specifically, participants completed the 12-item Self-Compassion Scale – Short Form, which measures the frequency of self-compassionate feelings on a day to day basis (anchored 1 = almost never to 5 = almost always). Items were averaged to form a composite measure of trait self-compassion, with negative items reverse-scored (α = 0.86; Neff, 2003b; Raes et al., 2011). Trait self-compassion was embedded among two other exploratory baseline questionnaires: the NEO Five-Factor Inventory (NEO-FFI) Extraversion subscale (Costa and McCrae, 1992), and the Dispositional Positive Emotions Scale (DPES) Compassion subscale (Shiota et al., 2006). Then, following existing procedures for testing compassionate feelings (Leary et al., 2007, Study 4), participants were videotaped while telling an extemporaneous children’s story beginning with, “Once upon a time, there was a little bear…” for 90 s. Participants, who believed we were collecting pilot data for an unrelated study, next completed a 3-min self-affirmation or control writing exercise as described in Study 1. Additionally, participants completed a 4-item manipulation check (α = 0.97) assessing whether the writing exercise was important to their self-identity. Specifically, participants rated the personal importance of the value they wrote about on a 6-point Likert scale (strongly disagree – strongly agree; i.e., “This value is an important part of who I am;” “In general, I try to live up to this value”).
Our present findings suggest that self-affirmation may increase feelings of self-compassion, and that self-compassion may be a promising new mechanism for a potentially broad range of self-affirmation effects. More research is needed, but the present research provides an initial suggestion that affirming an important personal value increases feelings of self-compassion for mobilizing a pro-social self.
Some experts, like John Pollock with the National Coalition for a Civil Right to Counsel, have focused on expanding the right to counsel in civil cases implicating basic human needs. Others have advocated for expansion of the right to counsel in lower-level criminal cases where the consequences – including obstacles to housing or employment, or deportation – can still be incredibly high.
Depositions: A deposition is a question-and-answer session where a party can ask her opponent questions. Depositions are transcribed by a court reporter (AKA stenographer). Depositions can be expensive, especially if videotaped. Deposition transcripts cost anywhere from $2-5 per page. A single transcript could cost hundreds of dollars. A video copy will cost extra.

(C) Fund Raising. A judge may assist nonprofit law-related, civic, charitable, educational, religious, or social organizations in planning fund-raising activities and may be listed as an officer, director, or trustee. A judge may solicit funds for such an organization from judges over whom the judge does not exercise supervisory or appellate authority and from members of the judge’s family. Otherwise, a judge should not personally participate in fund-raising activities, solicit funds for any organization, or use or permit the use of the prestige of judicial office for that purpose. A judge should not personally participate in membership solicitation if the solicitation might reasonably be perceived as coercive or is essentially a fund-raising mechanism.
The Sixth Amendment guarantees criminal defendants the right to representation by counsel.  In 1975, the Supreme Court held that the structure of the Sixth Amendment necessarily implies that a defendant in a state criminal trial has a constitutional right to proceed without counsel when he voluntarily and intelligently elects to do so. See Faretta v. California, 422 U.S. 806 (1975).  Thus, an unwilling defendant may not be compelled by the State to accept the assistance of a lawyer.  A defendant's right to self-represenatation in federal criminal proceedings is codified in 28 U.S.C. § 1654. 
Where does any novelist pick up any character? For the most part, in town, to be sure. Every great town is a kind of man-show, where the novelist goes for his stock, just as the agriculturist goes to the cattle-show for his. But in the one fair, new species of quadrupeds are hardly more rare, than in the other are new species of characters—that is, original ones.

University of Illinois Law School's Professor Robert Lawless, a national expert in personal credit and bankruptcy, showed that, the rate of non-attorney filings in bankruptcy courts by debtors was 13.8% for chapter 13 cases, and 10.1% for chapter 7 cases. The rate was as high as 30% to 45% for major urban areas, such as California and New York city. US Bankruptcy Court of Arizona reported 23.14% cases filed pro se in October 2011, up from 20.61% a year before.[41]

The judge in my case offered an angry and dismissive "Here we go!" when I argued that he must liberally construe the allegations in my complaint, as the 1972 Supreme Court precedent Haines v. Kerner dictates. He also disregarded the court's own local rules by denying my right to conduct my own voir dire of the prospective jurors, simply because I was proceeding pro se. He berated me in open court for my refusal to retain an attorney, and condescendingly informed me that he didn't think I would prevail at the trial. At various points, including when he urged me to accept the defendant's settlement offer, I felt he was trying to intimidate me simply because I chose to represent myself.


In New Hampshire one party is pro se in 85% of all civil cases in the district court and 48% of all civil cases in the superior court in 2004.[40] In probate court, both sides are unrepresented by lawyers in 38% of cases. In superior court domestic relations cases, almost 70% of cases have one pro se party, while in district court domestic violence cases, 97% of the cases have one pro se party.[1]

Attorney Bonanno's answers to questions are for general purposes only and do not establish an attorney-client relationship. You should carefully consider advice from an attorney hired and who has all facts necessary to properly advise a client, which is why these answers to questions are for general purposes only and do not establish an attorney-client relationship.
Judges support civil legal aid as a means of ensuring that the most vulnerable people in society can have decent, safe, and healthy lives. Adversarial proceedings regularly involve basic human needs, such as shelter, food, safety, health, and child custody. They regularly affect vulnerable groups such as senior citizens, domestic violence victims, and veterans with post-traumatic stress disorder.
A judge who is retired under 28 U.S.C. § 371(b) or § 372(a) (applicable to Article III judges), or who is subject to recall under § 178(d) (applicable to judges on the Court of Federal Claims), or who is recalled to judicial service, should comply with all the provisions of this Code except Canon 4F, but the judge should refrain from judicial service during the period of extrajudicial appointment not sanctioned by Canon 4F. All other retired judges who are eligible for recall to judicial service (except those in U.S. territories and possessions) should comply with the provisions of this Code governing part-time judges. However, bankruptcy judges and magistrate judges who are eligible for recall but who have notified the Administrative Office of the United States Courts that they will not consent to recall are not obligated to comply with the provisions of this Code governing part-time judges. Such notification may be made at any time after retirement, and is irrevocable. A senior judge in the territories and possessions must comply with this Code as prescribed by 28 U.S.C. § 373(c)(5) and (d).
During divorce proceedings, self-represented parties must adhere to the same rules and procedures as attorneys. This includes filing the necessary paperwork within the time limits specified in the rules of civil procedure, and being aware of what each hearing entails. For some people, the process in a pro se divorce can be more difficult if the other party is represented by an attorney.
The 2014 amendment to the Compliance section, regarding retired bankruptcy judges and magistrate judges and exempting those judges from compliance with the Code as part-time judges if they notify the Administrative Office of the United States Courts that they will not consent to recall, was not intended to alter those judges’ statutory entitlements to annuities, cost-of-living adjustments, or any other retirement benefits.
It sounds like you are on the right path and are doing things correctly. Since the defendant hasn’t complied with the rules and has failed to either admit, deny, or object to your requests, it seems clear that the judge will not have much other choice other than to issue an order deeming the matters as admitted under ORCP Rule 45. And congratulations for submitting requests for admissions, many pro se’s make the mistake of not submitting requests for admissions in their litigations. Requests for Admissions can be very crucial to a case and it is a mistake not to submit them to the opposing party. Hopefully the judge in your case will follow the governing rule and issue an order deeming the matters from your requests as admitted. That will certainly help you prove your case and as you said, will also potentially alleviate your having to drag some witnesses into court against their will to testify. Good for you for holding your own and overcoming the “overwhelming” factor and resisting folding your hand. And good for you for not allowing the defendant’s lawyer into bluffing you and trying to intimidate you into giving up. This is what unscrupulous lawyers try to do, and unfortunately, it works many times. It sounds like you are doing a great job holding your own. You are doing a great job on how you are handling the requests for admissions issues. Keep up the good work! I wish you the best!
Our research provides a promising indication of the pro-social benefits of self-affirmation and self-compassionate feelings. It is perhaps not surprising that feelings of compassion have been associated with increased helping behavior (Mikulincer et al., 2005; Hutcherson et al., 2008; Piff et al., 2010, Study 4), but no published studies (to our knowledge) have tested whether self-compassionate feelings can mobilize helping behavior. His Holiness The Dalai Lama poignantly stated this possibility when he said “If you don’t love yourself, you cannot love others. You will not be able to love others. If you have no compassion for yourself then you are not able of developing compassion for others.” Our study provides an initial experimental demonstration of this idea; we find that increasing feelings of self-compassion (via a self-affirmation activity) can mobilize helping behaviors (to a shelf-collapse incident). Thus self-affirmation may address internally derived self-threats (increasing self-compassion), which in turn allow one to transcend these self-concerns and focus on helping others. Our work joins previous work showing that self-compassion may also act as a buffer to self-threatening events and negative emotions (Neff, 2003a; Leary et al., 2007).
Reaching out to people close to us, even if just for a quick chat, is a great way to remember our vast self-worth. While it's not right to seek validation through others, it is definitely helpful to spend time with those who make us feel loved. People like this include our closest friends, our family, and our significant others. Feeling that you deserve the companies of others is an essential step in developing love for yourself.
So, you have to decide what your goal is: (1) To post your complaint on the web in all its vitriolic splendor and go down in a blaze of glory or (2) to win your case. If its the former, go for it! If its the latter, get some help to draft a complaint in law talk, keep it simple, and go for the bucks you need to survive. You can do that, and still keep the street war going in a forum other than the courtroom. That's the win-win approach.

When an individual acts on his own behalf during a legal action, rather than through an attorney, he is considered to be a pro se litigant. This Latin term literally means “advocating on one’s own behalf.” In all jurisdictions in the United States, an individual is allowed to represent himself, whether as the plaintiff or defendant in a civil lawsuit, or as the defendant in a criminal case. To explore this concept, consider the following pro se definition.
Pro se representation refers to a situation in which a person decides not to be represented by an attorney in a civil or criminal court case. The right of an individual to choose pro se representation dates back to pre-Constitutional times in the U.S. Although individuals have the right to represent themselves during legal actions, there are certain requirements. For example, the individual must have the mental capacity necessary to represent himself, which may be determined by the court, if questioned. Additionally, an individual choosing pro se representation must observe all of the rules of the legal action and the courtroom, just as an attorney would be expected to do.
I finally decided to invest in the program and start to learn "How to Win in Court"! Your program saved me. Learning the rules of court make a difference! The HOA dropped the case. Thank you for everything! I now can start my life over after 10 years of unfounded harassment from greedy people who don't care! The only regret is I did not order your program sooner. ... Becca C.
The civil legal needs of both low- and moderate-income individuals in the United States are not being met.2 The need for legal assistance by over one hundred million people in this country is dire.3 Today’s courts look nothing like the ideal. Around the country, state and federal courts regularly encounter pro se litigants: that is, litigants without attorney representation.4 When opposed by an adversary with a lawyer, litigants representing themselves often lose even when the merits of the case favor them. The imbalance leads to injustice.
Good prep for litigation is hard work, like reading cases and statutes and writing concise, precise and persuasive motions and pleadings. Even then, the “tactics in the courtroom” you mention can still go on. So, mentality can be just as important as hard tangible work. Understand that lawyers want to win too, and they’ll do whatever they think it takes to do so. Cutting the ethical edge is just a day at work for some of them. Your job is to not get up in your feelings about any of that stuff. I know that’s difficult to do, and I struggle with it all the time, but it does not help you win. Do the work, understand your arguments and stay on point.
Our replies to Avvo questions should not be considered specific legal advice to any individual, and no attorney-client relationship is formed with you. Our aim is to provide general principles that may be useful to the Avvo community as a whole. You should seek individual legal advice pertaining to your specific factual situation, and the laws applicable to your jurisdiction. Moore & Moore Attorneys at Law -- [email protected]
Do I have a basic understanding of the required court documents? Mounds of documents can be very intimidating to a lot of people, legal officials included. Parents considering pro se representation should become familiar with various types of family law documents. Again, become friendly with the court clerk and ask for his or her help identifying the correct forms, where to get them, when they are due, and how they should be submitted. 
An individual’s right to represent himself or herself in federal court is expressly codified in 28 U.S.C. § 1654 (2018), which provides: “In all courts of the United States the parties may plead and conduct their own cases . . . therein.” Similarly, many states have codified the rights of pro se litigants in their respective constitutions and statutes. Drew A. Swank, “The Pro Se Phenomenon,” 19 BYU J. Pub. L. 373, 375 (2005). Indeed, according to the Supreme Court, there is “no evidence that the . . . Framers ever doubted the right of self-representation, or imagined that this right might be considered inferior to the right of assistance of counsel.” Faretta v. California, 422 U.S. 806, 832 (1975).
Congress also has a role. In extreme cases it has the power to remove judges, of course. But short of that, it can at least underscore the seriousness of the rights it established for litigants in the Judiciary Act. Whether through binding or nonbinding language on the topic, Congress can make clear that complaints about violations of the rights of pro se litigants must be taken very seriously by judicial councils.

We tested two predictions in Study 2: (1) whether self-affirmation increased feelings of self-compassion but not compassionate feelings toward others, and (2) whether trait self-compassion moderates the self-affirmation self-compassion effect, such that self-affirmation would be more likely to increase self-compassionate feelings among participants who had pre-existing low levels of trait self-compassion. To test these predictions, we conducted a multiple regression analysis that modeled the self-affirmation × video condition interaction, and the 3-way trait self-compassion × self-affirmation × video condition interaction. Specifically, this multiple regression analysis included the trait self-compassion continuous predictor variable, self-affirmation condition (self-affirmation = 1 or control = 0), and video condition (self = 1 or other video = 0) as predictor variables, along with their two-way interactions, and one 3-way interaction term. Table ​Table11 provides the results of this multiple regression analysis for compassionate feelings to the storytelling video, and Figure ​Figure33 visually depicts the results. Notably, this regression analysis revealed a significant main effect of video condition, such that those who watched their own video had lower feelings of compassion than those who watched the confederate’s video [β = -2.31, t(69) = -3.96, p < 0.005]. Moreover, we observed a significant trait self-compassion × video condition interaction, showing that participants lower in trait self-compassion rated their own video less favorably relative to participants higher in trait self-compassion (whereas trait self-compassion did not impact ratings of a peer’s video). This result conceptually replicates previous research showing that trait self-compassion moderates behavioral self-compassion to a storytelling video (Leary et al., 2007).

Judges also support greatly increased funding for lawyers in civil cases for litigants who cannot afford representation out of self-interest. Most local and state judges are elected or appointed to serve for a specified term, to which they may be either reelected or reappointed.21 They are periodically evaluated by the public or the appointing authority. Judges perceived as showing partiality – for example, by providing permitted assistance to unrepresented litigants – may lose elections or reappointments. Judges’ careers can be marred by complaints from unrepresented litigants who, because they do not have the benefit of legal advice, have unreasonable expectations about courts and law.22 The presence of lawyers on both sides of a case insulates judges from perceptions of impartiality and from litigant complaints.
Yet the tone of the book isn’t quite satirical; it’s not exactly an indictment of the materialism and gullibility of American society. Melville’s confidence-man doesn’t try to persuade marks, not exactly. His method takes the form of a dialogue on why trust is better than mistrust, an argument for the need to have faith in nature and mankind. Much of the book is taken up with elaborate philosophical arguments on questions such as whether nature is always good, whether a boy’s character predicts the man he will become, the ethics of loaning money, and, above all, whether one should have confidence, or trust, in one’s fellow man. The effect is a bit as if Plato had Socrates, while arguing that justice is better than injustice, convince Glaucon to lend him his watch. It’s an odd book about materialism that spends all its time with its head in the clouds—although there’s no better time to pick a man’'s pocket than while he’s stargazing. There’s a slight scent of brimstone to the confidence-man, as if he’s come to earth as part of an infernal bet on the fallibility of human nature. Or, as the novel’s most caustic cynic, a one-legged man who believes that a crippled beggar called Guinea is a white man in blackface, says, “Money, you think, is the sole motive to pains and hazard, deception and deviltry, in this world. How much money did the devil make by gulling Eve?” Yet as it turns out, the philosophical claims the novel’s characters dispute, about human nature and the obligations of human beings toward each other, have much to do with the particular economic form of the society they inhabit.
Canon 2C. Membership of a judge in an organization that practices invidious discrimination gives rise to perceptions that the judge’s impartiality is impaired. Canon 2C refers to the current practices of the organization. Whether an organization practices invidious discrimination is often a complex question to which judges should be sensitive. The answer cannot be determined from a mere examination of an organization’s current membership rolls but rather depends on how the organization selects members and other relevant factors, such as that the organization is dedicated to the preservation of religious, ethnic or cultural values of legitimate common interest to its members, or that it is in fact and effect an intimate, purely private organization whose membership limitations could not be constitutionally prohibited. See New York State Club Ass’n. Inc. v. City of New York, 487 U.S. 1, 108 S. Ct. 2225, 101 L. Ed. 2d 1 (1988); Board of Directors of Rotary International v. Rotary Club of Duarte, 481 U.S. 537, 107 S. Ct. 1940, 95 L. Ed. 2d 474 (1987); Roberts v. United States Jaycees, 468 U.S. 609, 104 S. Ct. 3244, 82 L. Ed. 2d 462 (1984). Other relevant factors include the size and nature of the organization and the diversity of persons in the locale who might reasonably be considered potential members. Thus the mere absence of diverse membership does not by itself demonstrate a violation unless reasonable persons with knowledge of all the relevant circumstances would expect that the membership would be diverse in the absence of invidious discrimination. Absent such factors, an organization is generally said to discriminate invidiously if it arbitrarily excludes from membership on the basis of race, religion, sex, or national origin persons who would otherwise be admitted to membership.

The cost of providing attorneys for everyone who needs but cannot afford one would be huge. Providing just one hour of legal services to each person unable to afford it would cost an estimated $20–$25 billion.12 Courts cannot possibly cover this cost: cutbacks in court budgets by state legislatures mean that many courts cannot even cover their basic operating expenses.13 Few courts have money in their budgets to provide lawyers for the indigent. With $100 million for civil lawyers, New York State recently had more money for this purpose than any other state. Though the funding was far from enough to close the justice gap, the state saw a significant decline in the number of unrepresented litigants in the courts.14


Do your homework and educate the court. It is important, at the outset of a case, for trial counsel to determine if he or she is litigating against a wolf in sheep’s clothing. “When the pro se litigant is really an expert litigant, the court’s sympathy for his presumed inexpertise diminishes markedly.” Scott L. Garland, “Avoiding Goliath’s Fate: Defeating a Pro Se Litigant,” Litigation, Vol. 24, No. 2 (Winter 1998), at 45, 50 (1998). A search of the county or state docket may reveal that the pro se party has actually been involved in numerous lawsuits and maybe has even been deemed a vexatious litigant. Armed with this knowledge, counsel is better equipped to handle both interacting with the self-represented party and convincing the court that the pro se party’s failure to follow the rules warrants sanctions.
Eighty percent of state criminal defendants cannot afford to pay for a lawyer, and only those who are actually incarcerated are constitutionally entitled to appointed counsel. Many people facing misdemeanor charges can, if convicted, be subjected to significant fines and fees, or face the loss of benefits (including housing) or deportation. Yet, they have no right to an attorney, and those who cannot afford a lawyer will go without one.
Study 2 also provides some specificity around the relationship between self-affirmation and self-compassionate feelings; we did not find evidence that self-affirmation affected more general performance perceptions of the self or peer storytelling videos, though our study may be underpowered to detect subtle differences in this dimension of self-compassion. Though we do not definitively rule out this possibility, our results suggest that self-affirmation effects may be specific to affective measures of self-compassion, which is consistent with the affective change in self-compassion we observed in Study 1.
It sounds like you are on the right path and are doing things correctly. Since the defendant hasn’t complied with the rules and has failed to either admit, deny, or object to your requests, it seems clear that the judge will not have much other choice other than to issue an order deeming the matters as admitted under ORCP Rule 45. And congratulations for submitting requests for admissions, many pro se’s make the mistake of not submitting requests for admissions in their litigations. Requests for Admissions can be very crucial to a case and it is a mistake not to submit them to the opposing party. Hopefully the judge in your case will follow the governing rule and issue an order deeming the matters from your requests as admitted. That will certainly help you prove your case and as you said, will also potentially alleviate your having to drag some witnesses into court against their will to testify. Good for you for holding your own and overcoming the “overwhelming” factor and resisting folding your hand. And good for you for not allowing the defendant’s lawyer into bluffing you and trying to intimidate you into giving up. This is what unscrupulous lawyers try to do, and unfortunately, it works many times. It sounds like you are doing a great job holding your own. You are doing a great job on how you are handling the requests for admissions issues. Keep up the good work! I wish you the best!
Canon 3C(1)(d)(ii). The fact that a lawyer in a proceeding is affiliated with a law firm with which a relative of the judge is affiliated does not of itself disqualify the judge. However, if “the judge’s impartiality might reasonably be questioned” under Canon 3C(1), or the relative is known by the judge to have an interest in the law firm that could be “substantially affected by the outcome of the proceeding” under Canon 3C(1)(d)(iii), the judge’s disqualification is required.
Canon 4H. A judge is not required by this Code to disclose income, debts, or investments, except as provided in this Canon. The Ethics Reform Act of 1989 and implementing regulations promulgated by the Judicial Conference impose additional restrictions on judges’ receipt of compensation. That Act and those regulations should be consulted before a judge enters into any arrangement involving the receipt of compensation. The restrictions so imposed include but are not limited to: (1) a prohibition against receiving “honoraria” (defined as anything of value received for a speech, appearance, or article), (2) a prohibition against receiving compensation for service as a director, trustee, or officer of a profit or nonprofit organization, (3) a requirement that compensated teaching activities receive prior approval, and (4) a limitation on the receipt of “outside earned income.”
Canon 4F. The appropriateness of accepting extrajudicial assignments must be assessed in light of the demands on judicial resources and the need to protect the courts from involvement in matters that may prove to be controversial. Judges should not accept governmental appointments that could interfere with the effectiveness and independence of the judiciary, interfere with the performance of the judge’s judicial responsibilities, or tend to undermine public confidence in the judiciary.
Both of your suggestions are very helpful. It seems that if I were to appeal, it would not be for my upcoming Motion to Dismiss, because I understand that would be an ‘interlocutory’ appeal, and therefore not allowed. I also understand your point about the Judge & OC taking a pro se litigant much more seriously and cutting the nonsense by the very presence of a court reporter. In that respect, it makes a lot of sense in that a reporter may make an appeal unnecessary if the court decides to be reasonable and fair:)
DO NOT IGNORE IT.  You should always respond to a summons and complaint.  The correct way to respond is to go to the clerk’s office at the address provided on the summons and tell the clerk that you want to file an answer.  The clerk will give you an answer form and can help you to complete it.  For more detailed assistance filing your answer, contact the NYC Financial Justice Hotline at 212-925-4929.
Some courts issue orders against self representation in civil cases. A court enjoined a former attorney from suing the new lover of her former attorney.[27] The Superior Court of Bergen New Jersey also issued an order against pro se litigation based on a number of lawsuits that were dismissed and a failure to provide income tax returns in case sanctions might issue.[28] The Superior Court of New Jersey issued an order prohibiting a litigant from filing new lawsuits.[29] The Third Circuit however ruled that a restriction on pro se litigation went too far and that it could not be enforced if a litigant certified that he has new claims that were never before disposed of on the merits.[30] The 10th Circuit ruled that before imposing filing restrictions, a district court must set forth examples of abusive filings and that if the district court did not do so, the filing restrictions must be vacated.[31] The District of Columbia Court of Appeals wrote that "private individuals have 'a constitutional right of access to the courts',[32] that is, the 'right to sue and defend in the courts'."[33]
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