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The district court issued an order sua sponte that enjoined the clerk from accepting any future cases filed by Lonzy Oliver without a specific court order. Oliver had filed over 50 cases since 1969, all of which were deemed frivolous and created a substantial burden on the court. While courts have the power to restrict filings of meritless, repetitive claims, the Third Circuit determined Oliver should have been given notice and a chance to oppose the order before it was issued. The court vacated the order a

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