ASSIGNMENT OF COUNSEL
STANDARD OF REVIEW = ABUSE OF DISCRETION

We review a district court’s discovery rulings for abuse of discretion. Maynard v. Bd. of Regents, 342 F.3d 1281, 1286 (11th Cir.2003). We also review a district court’s decision not to appoint counsel for abuse of discretion. United States v. Berger, 375 F.3d 1223, 1226 (11th Cir.2004).