And while a court may consider a petitioner's limited education and lack of familiarity with the English language when analyzing the totality of his circumstances, Ramos-Martínez, 638 F.3d at 324, courts have held that a petitioner's limited English proficiency is an extraordinary circumstance for equitable tolling purposes "only when the petitioner faced other obstacles related to his or her linguistic difficulties." See, e.g., Roldan v. Reilley, No. 13-cv-447-PB, 2014 WL 3573596, at *3 & n.4 (D.N.H. July 21, 2014) (collecting cases and noting that some circuits have even concluded that limited English proficiency is never an extraordinary circumstance). Here, Aguilar has failed to identify other obstacles tied to his language barrier and has done so against a backdrop in which he was able to overcome that barrier and pursue and file other filings in this matter, albeit with assistance from fellow inmates.
Doc. No. 1. Roldan filed a petition for a writ of habeas corpus in this court. Id. Edward Reilley, the Warden at the facility where Roldan is incarcerated, filed a motion for summary judgment, Doc. No. 12, which I granted on July 21, 2014. Roldan v. Reilley, 2014 DNH 158, 13. Roldan now moves for a certificate of appealability pursuant to 28 U.S.C. § 2253(c). Doc. No. 18. I deny the motion.