With no explanation, chose the best option from "A", "B", "C" or "D". could be based”). Mr. Hernandez cannot avoid the consequences of his inadequate appellate briefing by incorporating his filings in the district court. As stated above, Mr. Hernandez’s application attempts to “incorporate[ ] by ... reference as though fully set forth hereat [sic], each and every allegation set forth in all prior filings in this matter.” Aplt. Application for COA at 2. This he cannot do. Under Tenth Circuit Rules, “[incorporating by reference portions of lower court or agency briefs or pleadings is disapproved.” 10th Cir. R. 28.4 (emphasis added). It should be patent that when the proposed incorporation is as all-encompassing as that sought by Mr. Hernandez, our disapproval results in an outright prohibition. See Wardell v. Duncan, 470 F.3d 954, 963-64 (10th Cir.2006) (<HOLDING>); Gaines-Tabb v. ICI Explosives, USA, Inc., 160

A: holding defendants pro se motion to reduce sentence was not properly before the trial court when defendant was represented by counsel since defendant may not proceed both by counsel and pro se
B: holding that courts must construe pro se filings liberally
C: holding that the appellant was not permitted to incorporate district court filings into an appellate brief by reference and that his pro se status did not except him from such established rules
D: holding that a defendant proceeding pro se is bound by same rules as party represented by counsel and a court cannot allow pro se litigant lower standard of performance
C.