With no explanation, chose the best option from "A", "B", "C" or "D". way from exercising his rights.’ ” Id. (quoting Johnson v. Nyack Hosp., 86 F.3d 8, 12 (2d Cir.1996)). A litigant seeking equitable tolling “bears the burden of establishing two elements: (1) that he has been pursuing his rights diligently, and (2) that some extraordinary circumstance stood in his way.” Pace v. DiGuglielmo, 544 U.S. 408, 418, 125 S.Ct. 1807, 161 L.Ed.2d 669 (2005) (citing Irwin v. Department of Veterans Affairs, 498 U.S. 89, 96, 111 S.Ct. 453, 112 L.Ed.2d 435 (1990)). Pro se filings, although held to more lenient standards, are not excused from establishing these elements. See, e.g., Valverde v. Stinson, 224 F.3d 129, 133 (2d Cir.2000) (applying general equitable tolling principles against pro se litigant); see also Doe v. Menefee, 391 F.3d 147, 175 (2d Cir.2004) (<HOLDING>). Here, Arias-Mieses has not shown that “an

A: holding that pro se status does not in itself constitute an extraordinary circumstance meriting tolling
B: holding that mental incapacity is an extraordinary circumstance that may warrant equitable tolling
C: holding petitioners pro se status did not constitute adequate cause for failure to raise claims earlier
D: holding that inability to obtain court documents did not constitute extraordinary circumstance
A.