S.Ct. 1621, 52 L.Ed.2d 136 (1977), we are not troubled by this aspect of the district court’s ruling. 4 . In addition, Mr. Eatman appears to challenge thé district court’s ruling that his reply brief was not properly filed because it was not signed under penalty of perjury. Because he does not explain what bearing this point might have on his request for a COA, we will not discuss the argument further. 5 . Mr. Eatman purports to incorporate by reference his reply brief from the § 2255 proceedings in the district court. We will not permit him to do so. See 10th Cir. R. 28.4 ("Incorporating by reference portions of lower court or agency briefs or pleadings is disapproved [under the Federal Rules of Appellate Procedure].”); see also Wardell v. Duncan, 470 F.3d 954, 963-64 (10th Cir. 2006) (<HOLDING>). Consequently, we will not address the
holding that this court was unable to reach alleged errors where pro se appellant did not provide an adequate record holding that courts must construe pro se filings liberally holding that although pro se litigants are entitled to liberal construction of their pleadings pro se litigants must follow procedural rules holding that an appellant was not entitled to incorporate district court filings into his appellate brief by reference and that his pro se status did not except him from such established rules 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