Read the following excerpt from a US court opinion:
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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) . Thus, a petitioner’s initial pro se habeas
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What is the most suitable continuation to the opinion? Your options are:
A. holding petitioners pro se status did not constitute adequate cause for failure to raise claims earlier
B. holding that this court was unable to reach alleged errors where pro se appellant did not provide an adequate record
C. holding that pro se status does not in itself constitute an extraordinary circumstance meriting tolling
D. holding that pro se petitioners need not raise issues in ins terms but may raise them as they may have understood them
E. holding a court can restrict future pro se pleadings if it first provides a pro se litigant notice and an opportunity to respond
Reply with [A, B, C, D, E] only.