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Robert Sykes, an employee of the Virginia Department of Corrections, filed a Section 1983 lawsuit alleging that defendants conspired to prevent him from obtaining employment. The district court granted judgment for the defendants after a hearing. On appeal, Sykes argued that the district court erred by not issuing subpoenas, by requiring him to respond to a summary judgment motion at the hearing rather than allowing a written response, and by denying him appointed counsel. The appellate court affirmed the d

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