The following excerpt is from Virgo v. Sherman, No. 2:15-cv-1518 MCE KJN P (E.D. Cal. 2016):
for a habeas petitioner because it does not protect a petitioner's unexhausted claims from expiring during a stay. See King, 564 F.3d at 1140-41. See also Duncan v. Walker, 533 U.S. 167, 172-75 (2001) (unlike the filing of a state habeas petition, the filing of a federal habeas petition does not toll the statute of limitations).
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