Opinion for the Court filed by Circuit Judge RANDOLPH.
RANDOLPH, Circuit Judge:
This case presents an issue of first impression for this circuit: what criteria should guide district courts in deciding motions for the appointment of counsel in cases brought under the Freedom of Information Act, 5 U.S.C. § 552 ("FOIA")?
James A. Willis is serving time for drug offenses. He filed a FOIA action in 1996 seeking the release of numerous documents. The...
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