With no explanation, chose the best option from "A", "B", "C" or "D". risk inadvertently foreclosing his right to pursue certain constitutional claims by ignorantly filing a petition that excluded those claims. After McCleskey, however, this is precisely the “trap for the unwary pro se petitioner” of which Justice Blackmun warned. Since a prisoner has no right to counsel in habeas proceedings, see Coleman, — U.S. at -, 111 S.Ct. at 2566, the initial habeas petition is typically filed pro se, or at best with the assistance of jailhouse lawyers who are notoriously unreliable. The absence of a right to counsel in habeas proceedings means that lack of counsel does not constitute cause under the McCleskey rule for a pro se petitioner’s failure to raise a claim in his initial habeas petition. See, e.g., Rodriguez v. Maynard, 948 F.2d 684, 688 (10th Cir.1991) (<HOLDING>). Thus, a petitioner’s initial pro se habeas

A: holding that pro se petitioners need not raise issues in ins terms but may raise them as they may have understood them
B: holding that this court was unable to reach alleged errors where pro se appellant did not provide an adequate record
C: holding petitioners pro se status did not constitute adequate cause for failure to raise claims earlier
D: holding that pro se status does not in itself constitute an extraordinary circumstance meriting tolling
C.