With no explanation, chose the best option from "A", "B", "C" or "D". three additional bases for equitably tolling § 2244(d)’s one-year limitation period: (1) "his lack of access to legal resources,” (2) "his lack of legal knowledge,” and (3) his "medical disability” (depression). R. at 64. In his filings with this court, however, Mr. Sandoval does not renew these claims. Instead, he simply states that he "explained the circumstances beyond [his] control” during "habeas review.” Aplt. Opening Br. for Appl. for COA at 2. Insofar as this could be read as an attempt to incorporate the three arguments by reference, this practice is generally disfavored in this circuit. See 10th Cir. R. 28.4 (“Incorporating by reference portions of lower court or agency briefs or pleadings is disapproved.”); see also Wardell v. Duncan, 470 F.3d 954, 963-64 (10th Cir.2006) (<HOLDING>); Gaines-Tabb v. ICI Explosives, USA, Inc., 160

A: holding that courts must construe pro se filings liberally
B: holding that the appellant could not incorporate district court filings into his appellate brief by reference and that his pro se status did not except him from such established rules
C: holding that nonlawyer proceeding pro se could not represent his children
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
B.