1.   Because the number of pro se cases has swelled, a sprawling network of self-help legal centers has blossomed across the nation.

2.   He said that more than anything else the Internet had made pro se cases easier to undertake.

3.   Primomo said pro se cases, in which individuals act as their own attorneys, are very rare.

4.   Prosecutors who have tried pro se cases, as these trials are called, say they are often forced to respond to frivolous requests and delaying tactics.