3. Pro se.

The availability of attorney’s fees to a plaintiff who prevails in an FOIA action is intended to make access to legal services easier. Mich. Comp. Laws Ann. § 15.240(6).   See Omdahl v. Iron County Board of Education, 478 Mich. 423, 733 N.W. 2d 380 (2007) (the fact that a plaintiff is a licensed attorney does not mean that the plaintiff has an attorney, and therefore, the plaintiff may not recover attorney’s fees); Watkins v. Manchester, 220 Mich. App. 337, 559 N.W. 2d 81 (1996) (pro se plaintiff-attorney cannot recover attorney’s fees under FOIA).