The following excerpt is from Garmon, In re, 572 F.2d 1373 (9th Cir. 1978):
The District of Columbia Circuit in United States v. Liddy, supra, arrived at the same result in a different fashion. It noted that there were many situations in which the running of a prison term is interrupted, postponing the date of the termination of the sentence. Two examples are a prisoner who escapes from prison and a parolee who commits offenses which lead to the revocation of his parole, requiring him to serve the portion of his sentence that remained when he was paroled. Thus 3568 was never intended to reach cases in which a sentence would be interrupted owing to some "fault of the prisoner." A recalcitrant prison witness similarly interrupts his sentence because of his intentional refusal to testify before the grand jury.
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