544 U.S. 408, 418, 125 S.Ct. 1807, 161 L.Ed.2d 669 (2005) (citing Irwin v. Department of Veterans Affairs, 498 U.S. 89, 96, 111 S.Ct. 453, 112 L.Ed.2d 435 (1990)); see also Smith v. McGinnis, 208 F.3d 13, 17 (2d Cir.2000) (stating that equitable tolling requires a showing that “the party seeking equitable tolling must have acted with reasonable diligence throughout the period he seeks to toll” and “extraordinary circumstances prevented him from filing his petition on time”) (citations omitted). Pro se filings, although held to more lenient standards, are not excused from establishing these elements. See, e.g., Valverde v. Stinson, 224 F.3d 129 (2d Cir.2000) (applying general equitable tolling principles against pro se litigant); see also Doe v. Menefee, 391 F.3d 147, 175 (2d Cir.2004) (<HOLDING>). B. APPLICATION Felluss argues that the
holding that a pro se prisoners incarceration before the enactment of the aedpa and his lack of notice of the statute of limitations does not present an extraordinary circumstance warranting equitable tolling holding that mental incapacity is an extraordinary circumstance that may warrant equitable tolling holding petitioners pro se status did not constitute adequate cause for failure to raise claims earlier holding that inability to obtain court documents did not constitute extraordinary circumstance holding that pro se status does not in itself constitute an extraordinary circumstance meriting tolling