The following excerpt is from Winn v. Foulk, No. 2:13-cv-02111 KJM AC P (E.D. Cal. 2015):
because they were raised on different sets of facts); United States v. Duffus, 174 F.3d 333, 337-38 (3d Cir.1999) (claim of ineffective assistance of counsel for failing to move to suppress evidence did not relate back to claim of ineffective assistance of counsel for failing to contend on appeal that evidence was insufficient to support conviction).
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