41, 44 (2d Cir.2004); Jorgensen v. Epic/Sony Records, 351 F.3d 46, 50 (2d Cir.2003); Bennett v. Goord, 343 F.3d 133, 137 (2d Cir.2003); Weixel v. New York City Bd. of Educ., 287 F.3d 138, 145-46 (2d Cir.2002); Cruz v. Gomez, 202 F.3d 593, 597 (2d Cir.2000); McPherson v. Coombe, 174 F.3d 276, 280 (2d Cir.1999); Graham v. Henderson, 89 F.3d 75, 79 (2d Cir.1996). This policy of liberally construing pro se submissions is driven by the understanding that “[implicit in the right of self-representation is an obligation on the part of the court to make reasonable allowances to protect pro se litigants from inadvertent forfeiture of important rights because of their lack of legal training.” Traguth v. Zuck, 710 F.2d 90, 95 (2d Cir.1983); see also Ruotolo v. I.R.S., 28 F.3d 6, 8 (2d Cir.1994) (<HOLDING>). See generally Jonathan D. Rosenbloom,
holding that although pro se litigants are entitled to liberal construction of their pleadings pro se litigants must follow procedural rules recognizing that although pro se litigants are not entitled to greater rights than represented litigants due process principles permit the imposition of a procedural bar only after consideration of the pro se litigants reasonable expectations about what had occurred holding that rule 56f applies to pro se litigants recognizing that pro se litigants must be accorded special solicitude holding that leniency should be accorded to pro se litigants when the defect in a complaint is merely procedural and there are potential grounds for relief