With no explanation, chose the best option from "A", "B", "C" or "D". unaware of the need to file affidavits and other responsive papers in opposition to the government’s motion to avoid summary judgment against him. In support of his argument, he cites authority from the Ninth and Eleventh Circuits: Rand v. Rowland, 113 F.3d 1520, 1522-23 (9th Cir.1997), and United States v. One Colt Python .357 Caliber Revolver, 845 F.2d 287 (11th Cir.1988). The majority of circuits have held that a pro se litigant is entitled to notice of the consequences of a summary judgment motion and the requirements of the summary judgment rule. See, e.g., Klingele v. Eikenberry, 849 F.2d 409, 411 (9th Cir.1988) (reaffirming its agreement with the rule providing pro se prisoners with notice of the summary judgment requirements); Graham v. Lewinski, 848 F.2d 342, 344 (2d Cir.1988) (<HOLDING>); One Colt Python .357 Cal. Revolver, 845 F.2d

A: holding that in all fairness a pro se litigant who is unaware of his obligation to respond should not have summary judgment entered against him
B: holding a court can restrict future pro se pleadings if it first provides a pro se litigant notice and an opportunity to respond
C: holding that pro se litigant who appeared in court under belief that her appearance was all that was needed to respond to summary judgment established that her failure to respond or ask for extension of time were mistakes based on misunderstanding of law and satisfied wheeler test
D: holding that a pro se litigant who is an attorney is not entitled to fees under  1988
A.